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2022 (2) TMI 1189 - AT - Income TaxReopening of assessment u/s 147 - unexplained bank deposits - valid approval from the appropriate authority as contemplated u/s 151 or not? - non application of mind by the approving authority, viz. Additional CIT-Range VI, Pathankot - HELD THAT:- As in case of the assessee before us the prescribed authority, viz. Additional CIT-Range VI, Pathankot had granted the approval u/s 151 of the Act in a mechanical manner, i.e, without application of mind to the facts of the case as were there before him, therefore, the assessment framed by the AO u/ss. 147/143(3) of the Act, dated 24.02.2014 cannot be sustained and is liable to be vacated on the said count itself. Accordingly, for want of valid assumption of jurisdiction by the AO the assessment framed by him u/s 147/143(3) of the Act, dated 24.02.2014 is herein quashed. - Decided in favour of assessee.
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