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2021 (6) TMI 1060 - ITAT AMRITSARReopening of assessment u/s 147 - addition on account of cash deposit in bank account - assessee challenged reopening on non-complying with mandatory requirement and conditions envisaged under section 151 - HELD THAT:- JCIT, Range-1, Jalandhar recorded the satisfaction in a mechanical manner without application of mind reopening under section 148 of the Act on the basis of mechanical approval without applying the mind by the Ld. Pr.CIT was not valid. Therefore, in the present case, the reopening of the assessment on the basis of notice under section 148 of the Act is quashed. Since the A.O. reopened the assessment under section 147 of the Act by issuing the notice under section 148 of the Act, on the basis of mechanical approval, without applying his mind, therefore the said approval was not valid and consequently the reopening of the assessment on the basis of said approval was not valid. We therefore quash the same - Decided in favour of assessee.
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