2025 (4) TMI 414 - SCH - Income Tax

Validity of reopening of assessment - reasons to believe - required approval of the Commissioner of Income Tax - As decided by HC 2024 (9) TMI 1134 - PATNA HIGH COURT AO had recorded reasons for believing that there was income escaping assessment which reasons were also appended to the request for approval made to the Commissioner. The Commissioner had obviously read the reasons and made a written order that he was satisfied on the basis of reasons recorded that this was a fit case for notice issued under Section 148. There is no requirement for the Commissioner to record his own reasons and it would suffice that he records the satisfaction regarding the reasons recorded by the Assessing Officer. Thus no reason to interfere with the notice issued under Section 148. HELD THAT - No good ground and reason to interfere with the impugned judgment; hence the present special leave petition is dismissed.

Summary

The Supreme Court, composed of Chief Justice Sanjiv Khanna, Justice Sanjay Kumar, and Justice K.V. Viswanathan, issued an order regarding a special leave petition. The Court, after hearing the counsel, decided to condone the delay but found "no good ground and reason to interfere with the impugned judgment." Consequently, the special leave petition was dismissed. All pending applications related to the case were also disposed of.