The assessment officer (AO) initiated reassessment proceedings...

The assessment officer (AO) initiated reassessment proceedings u/s 147 of the Act, citing Section 147(b) as the basis for approval, which is a non-existent provision. The sanctioning authority granted approval without considering this vital aspect, indicating a lack of independent application of mind and inquiry into the matter. The approval was granted mechanically and perfunctorily, without providing minimal reasons for satisfaction. The transaction in question involved parties other than the assessee. The reasons recorded for exercising jurisdiction u/s 147 were plagued with critical defects, rendering the reassessment proceedings invalid u/s 292B of the Act. Consequently, the reassessment proceedings were held to be bad in law, and the assessee's appeal was allowed.

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