Case Law Details
Tralochan Singh Vs ITO (ITAT Amritsar)
As regards to the validity of the reassessment proceedings under section 147 r.w.s 148 of the Act, it is not in dispute that the A.O. is required to get the approval of the competent authority i.e; JCIT in the present case. JCIT mentioned as under:
“ Yes, it is a fit case to issue notice under section 148 of the Income Tax Act.
From the aforesaid approval given by the JCIT, Range-1, Bathinda, it is clear that the satisfaction has been recorded in a mechanical manner, without applying the mind, for issuing the notice under section 148 of the Act.
In view of the above ITAT quashes reopening of the assessment under section 147 of the Act by issuing the notice under section 148.
Please become a Premium member. If you are already a Premium member, login here to access the full content.
