The assessment reopening u/s 147 read with Section 148 was found to be unsustainable due to the lack of...

The assessment reopening u/s 147 read with Section 148 was found to be unsustainable due to the lack of independent application of mind by the Commissioner of Income Tax (CIT) in granting approval. The CIT's approval was given in a slipshod manner without recording their own satisfaction, rendering the subsequent notice u/s 148 and assessment proceedings invalid. The addition made u/s 69 was also found to be improper as the Assessing Officer (AO) failed to invoke or apply any specific provision of law while making the addition. The AO did not specify the head under which the addition was made, whether business income, capital gains, or u/ss 48, 56, 68, or 69. Making an addition without invoking the relevant provision of the Act is against t..... .....

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