ITAT Delhi Quashes Section 147 and 148 Proceedings Over Improper Section 151 Sanction

Guljar Vs ITO (TDS) (ITAT Delhi)

Approval First, Reasons Later? ITAT Delhi Strikes Down Entire 147 Proceedings-148 Notice Void for Pre-Dated Sanction

In this appeal, Guljar challenged the reassessment framed u/s 147/148 on the ground that the AO recorded reasons for reopening after obtaining sanction u/s 151, rendering the approval invalid in the eyes of law. The AO recorded reasons on 30.03.2016, stating that cash deposits of ₹55,12,000 had escaped assessment. However, the sanction from PCIT was granted two days e

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