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Income Tax - Highlights / Catch Notes

Home Highlights March 2021 Year 2021 This

Reopening of assessment u/s 147 - validity of sanction-order ...


Court Questions Validity of Sanction Order in Reopened Tax Assessment u/ss 147 and 151 of Income Tax Act.

March 30, 2021

Case Laws     Income Tax     HC

Reopening of assessment u/s 147 - validity of sanction-order passed u/s 151 - because of the failure on the part of respondent no.1 to correlate the information received with the ostensible formation of belief by him, respondent no.2 attempted to connect, via her counter-affidavit, that the escaped income with the “suspicious” unsecured loan entries reflected in the assessee's returns for AY 2010-2011 and 2011-2012. As correctly argued by Mr. Kochar, the counter-affidavit and the submissions made across the bar cannot be used to sustain the impugned actions. - HC

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