Reopening Quashed – Reasons Based on Wrong Facts Mechanical 151 Approval; Rule-27 Legal Ground Allowed

ITO Vs Anushreya Investment Private Limited (ITAT Kolkata) Revenue filed appeal against deletion of ₹3,32,62,350 added u/s 68 as alleged bogus short-term capital loss. Assessee, without filing cross-appeal, invoked Rule 27 challenging the validity of reassessment u/s 147/143(3) on the ground that the very notice u/s 148 (27.03.2018) was void, being founded on (i) wrong & vague reasons, and (ii) invalid mechanical approval u/s 151. AO recorded wrong facts & vague reasons AO reopened assessment alleging bogus STCL of ₹2,95,99,250 in JMD Telefilms and ₹36,63,100 in Nivyah Infrastruc...