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2021 (9) TMI 329 - AT - Income TaxValidity of reopening of assessment u/s 147 - valid satisfaction recorded by the Ld. JCIT under section 151 or not? - mandation of approval of the competent authority i.e; JCIT - addition of capital gain - HELD THAT:- As relying on Shri Satnam Singh, Jalandhar [2021 (6) TMI 1060 - ITAT AMRITSAR] approval given by the JCIT, Range-1, Bathinda, it is clear that the satisfaction has been recorded in a mechanical manner, without applying the mind, for issuing the notice under section 148 of the Act - reopening of the assessment under section 147 of the Act by issuing the notice under section 148 of the Act is quashed - Decided in favour of assessee.
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