Reassessment - Assessment was completed u/s 143(3) - The investigation had been conducted and on the basis of information received, the Assessing Officer formed a prima facie or tentative opinion that the assessee had received bogus credit entries of Rs.42,03,250/- from the parties mentioned in the table - the information provided by the Directorate of Income Tax Investigation was not available with the Assessing Officer during the course of the first/original proceedings - Decided against the assessee.
Regarding approval u/s 151 - assessee submits that one of the conditions raised by the assessee was that there was no valid approval under Section 151 of the Act and the said aspect has not been examined by the tribunal as they had decided the appeal as noticed above on a different contention/argument. It will be open to the tribunal to examine the question whether or not there was a valid approval under Section 151 of the Act and decide the appeal of the Revenue on merits. - Matter remanded back to tribunal.
