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TMI Blog2018 (4) TMI 1535X X X X Extracts X X X X X X X X Extracts X X X X ..... d that the proceedings may be initiated under Section 147. Having regard to these facts, we are of the opinion that Soyuz (2015 (3) TMI 278 - DELHI HIGH COURT) has no application. The appeal is without merit and consequently, it is dismissed. - Decided against assessee. - ITA 464/2018 - - - Dated:- 17-4-2018 - S. Ravindra Bhat And A. K. Chawla, JJ. For the Appellant : Mr. G. C. Srivastava ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... had held that it is the official authorized by law only, who is entitled to initiate re-assessment proceedings and none-else. The ITAT s order went into issue of competence of the authority who sanctioned the re-assessment notice. The discussion by the ITAT in the impugned order is as follows: 6.We have considered the rival submissions and the orders of the authorities below in the light of r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to the Addl. DIT, who was the competent authority envisaged u/s. 151, for perusal and approval and the Addl. DIT after due application of his mind recorded his satisfaction as under: We may proceed to reopen the case u/s. 147 as proposed above. I am satisfied that this is a fit case for issue of notice u/s 148. 7. This noting of the Addl. DIT, in our considered opinion, does constit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t be supported. The appellant has also annexed a copy of the AO s reasons, prior to the issuance of the notice under Section 148. It clearly reveals that the concerned authority authorized by statute i.e. the Joint Commissioner, had clearly stated that the proceedings may be initiated under Section 147. Having regard to these facts, we are of the opinion that Soyuz (supra) has no application ..... X X X X Extracts X X X X X X X X Extracts X X X X
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