Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
Mechanical approval under search assessment law vitiates assessments when sanction lacks application of mind; retrospective curative provision cannot ...
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Reassessment u/s 147 - Sanction granted by the CIT u/s 151 - simply written “Yes I agree” which does not in any manner shed any light as to whether there was any application of mind at all by the Pr.CIT, - When a superior authority is given power by the legislature, to grant sanction to then that power needs to be exercised with due care and circumspection and after due application of mind - reassessment quashed
Reassessment u/s 147 - Sanction granted by the CIT u/s 151 - simply written “Yes I agree” which does not in any manner shed any light as to whether there was any application of mind at all by the Pr.CIT, - When a superior authority is given power by the legislature, to grant sanction to then that power needs to be exercised with due care and circumspection and after due application of mind - reassessment quashed
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