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Reopening of assessment u/s 147 - There is a mistake in the reasons recorded for reopening and according to respondents it is a typographical error that the figure of ₹ 3.02 lakhs was mentioned instead of ₹ 293.24 lakhs. In our view, this mistake demonstrates non-application of mind by respondent No.1 at the time of recording of the reasons for reopening the assessment. Though we do not find the approval under section 151 of the Act in the record and proceedings, we can certainly hazard a guess that even the Approving Authority would not have applied its mind or read the reasons recorded before granting approval. - Notice quashed - HC
Reopening of assessment u/s 147 - There is a mistake in the reasons recorded for reopening and according to respondents it is a typographical error that the figure of ₹ 3.02 lakhs was mentioned instead of ₹ 293.24 lakhs. In our view, this mistake demonstrates non-application of mind by respondent No.1 at the time of recording of the reasons for reopening the assessment. Though we do not find the approval under section 151 of the Act in the record and proceedings, we can certainly hazard a guess that even the Approving Authority would not have applied its mind or read the reasons recorded before granting approval. - Notice quashed - HC
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