CIT sanction without application of judicious mind is invalid- section 151

Swami Keshwanand Sikshan Sansthan Vs ITO (ITAT Jaipur)

Facts- Assessee deposited INR 92,41,500 with a banking company but didn’t filed any ROI for AY 2012-13. Therefore, the source of cash deposited remained unexplained and the case was reopened u/s 147. After making detailed inquiry, AO completed the assessment u/s 143(3) r.w.s 147 assessing total income as INR 2,87,97,100.

Assessee argued that AO initiated action u/s 147 and issued notice u/s 148 on 25.03.2019. Assesse

Please become a Premium member. If you are already a Premium member, login here to access the full content.