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2023 (5) TMI 1222 - AT - Income TaxReopening of assessment u/s 147 - accommodation entry receipts - reason to believe - HELD THAT:- It is pertinent to mention that even at the time of initiating the reassessment proceedings the AO himself was not sure about the mode of accommodation entry/allege transactions therefore reason to believe had no legs to stand. Therefore ground of assessee deserve to be allowed. Valid approval u/s. 151 - HELD THAT:- As relying on M/S N.C. CABLES LTD. [2017 (1) TMI 1036 - DELHI HIGH COURT] in the present case also the exercise of approving powers u/s. 151 of the Act appears to have been only ritualistic and formal rather than based on application of mind to the material placed by the AO before the approving authority which could lead to a valid and meaning full approval. Therefore notice u/s. 148 of the Act without obtaining valid approval u/s. 151 of the Act and all consequent reassessment and first appellate order are not validly sustainable and deserve to be quashed - Decided in favour of assessee.
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