Assessment U/s. 147 not become invalid for satisfaction of Reasons recorded by both CIT & JCIT

Mayurbhai Mangaldas Patel Vs. Income Tax Officer (ITAT Ahemdabad) that in the present case the Joint/Additional Commissioner of Income-tax has categorically expressed his satisfaction about the fact that on the reasons recorded by the Assessing Officer, it is fit case for issuance of notice under section 148. The requirements of approval under section 151 are thus clearly Satisfied. Merely because an even higher authority has expressed similar satisfaction does not obliterate the satisfaction of appropriate authorities. What we have seen in this particular case appears to be a part of the stan...