#Section 148
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Approval for Section 148 notice by mere “YES” word is invalid
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Section 147/ 151: Sanction granted by superior officer is not relevant
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Reassessment without disposing assessee’s objections by a speaking order is invalid
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Reassessment proceedings on basis of change of opinion was invalid
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S. 147/148 AO cannot review his decision & reopen on a change of opinion
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Mere signing against a particular column of format is nothing but a mechanical approval
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Reopening of Assessments after 4 Years -Section 148 -Income Tax Act – Special Considerations
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Approval to issue Section 148 notice has to be given by JCIT & not by PCIT
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Section 10AA Deduction allowable on enhanced profits after considering section 69C disallowance
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AO cannot reject Section 54 exemption if amount was deposited in capital gain deposit account
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After conclusion of proceedings u/s 147 AO cannot take aid of Exp. 3 to Section 147 to make any addition
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Reassessment not valid if assessee’s objections to reasons for reopening not disposed
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Income Tax
Non-quoting of reasons for reopening in reassessment notice would not vitiate entire proceedings
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Income Tax
