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2022 (12) TMI 429 - AT - Income TaxReopening of assessment u/s 147 - Necessity of obtaining of approval u/s 151 of the Act from the competent authority - AO proceeded on the basis of AIR information and issued a verification letter -HELD THAT:- As concluded that the AO has not obtained mandatory approval under sub-section (1) of section 151 of the Act before issuing notice u/s 148 of the Act from the competent authority, therefore, this omission vitiates the reassessment proceedings, notice u/s 148 of the Act and consequent reassessment order dated 05.12.2016 being bad in law and without assuming valid jurisdiction by the AO as per the mandate of section 151 of the Act. Therefore, on this count, legal ground of the assessee is allowed and reassessment proceedings, notice u/s 148 of the Act and consequent impugned assessment order are quashed. - Decided in favour of assessee.
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