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2017 (3) TMI 1860 - AT - Income TaxValidity of reopening of assessment u/s 147 - assumption of jurisdiction by the AO for reassessment - Validity of approval/sanction of the Addl. DIT - HELD THAT:- As rightly contended, in “United Electrical" [2002 (10) TMI 86 - DELHI HIGH COURT] it has been held that the Commissioner (herein Addl. DIT) is required to apply his mind to the proposal put to him for approval in the light of the material relied on by the AO; that the said power cannot be exercised casually and in a routine manner. In that case, as in the present one, the Addl. Commissioner had stated: “Yes it is a fit case for issue of notice u/s 148”. The reassessment proceedings were held to be invalid. Thus the assumption of jurisdiction for reassessment is bad in law - Decided in favour of assessee.
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