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2019 (6) TMI 917 - AT - Income TaxReopening of assessment u/s 147 - notice issued without the approval of the designated authority Addition u/s 68 on account of share capital - Failure to prove the genuineness and creditworthiness of the shareholders who have invested in the Company - summons u/s 131 issued to Director of assessee company and also to the shareholder, remained uncomplied with - HELD THAT:- The notice has been issued prior to the approval. Thus, reopening u/s 148 is without the approval of the designated authority and as such reassessment itself is bad and without any jurisdiction. The mandatory conditions of Section 148 has not at all followed by Revenue. Therefore, the re-opening itself is void ab initio and does not survive. - Decided in favour of assessee.
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