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ITAT Delhi quashes reassessment for quoting repealed section & granting mechanical Approval
Case Law Details
- Case Name
- Sumit Suneja Vs ACIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2011-12
- Courts
- All ITAT, ITAT Delhi
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Sumit Suneja Vs ACIT (ITAT Delhi)
Assessee’s case was reopened u/s 147 based on information of cash deposits (Rs 38,72,062 in PNB & Rs 2,10,600 in South India Bank). Assessee did not respond during assessment, leading to a best judgment order u/s 144, adding Rs40,82,662 as unexplained deposits.
Assessee’s contended that reassessment invalid for non-compliance with mandatory requirements of section 147/148 and that Approval u/s 151 was mechanical & without independent application of mind. AO mentioned non-existent section “147(a)” in approval form (provisions ...
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