ITAT quashes section 147 proceeding as approval was granted by JCIT without verifying recorded reasons  

Shri Tehmul B. Sethana Vs DCIT (ITAT Ahmedabad) It is mandatory to obtain the approval under the provisions of section 151 of the Act from the JCIT for initiating the proceedings under section 147 of the Act which will commence only after recording the reason to believe for the escapement of income. For initiating proceeding under section 147, the AO based on the fresh tangible material available before him requires to record the reasons to believe that income has escaped assessment. Thereafter, the AO before issuing notice under section 148 of the Act for initiation of reopening of the assess...