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The Supreme Court disposed of the special leave petition as withdrawn, allowing the petitioner to raise the contention regarding the validity of sanction granted by the competent authority before issuing the notice of reopening assessment u/s 147 before the High Court through an appropriate application. The High Court had previously held that the Additional Commissioner of Income Tax had applied their mind and granted sanction in an integrated exercise, conveying satisfaction to the Assessing Officer separately. The High Court found no reason to believe there was a non-application of mind. However, the petitioner contended that this factual issue was raised before the High Court but not considered in the impugned judgment. The Supreme Court noted that while this contention was recorded in its order issuing notice, it was not agitated before the High Court according to the impugned judgment. Since the petitioner submitted that the contention was indeed raised at the hearing but not noted by the High Court, the Supreme Court permitted the petitioner to withdraw the special leave petition and file an appropriate application before the High Court to address this issue.
The Supreme Court disposed of the special leave petition as withdrawn, allowing the petitioner to raise the contention regarding the validity of sanction granted by the competent authority before issuing the notice of reopening assessment u/s 147 before the High Court through an appropriate application. The High Court had previously held that the Additional Commissioner of Income Tax had applied their mind and granted sanction in an integrated exercise, conveying satisfaction to the Assessing Officer separately. The High Court found no reason to believe there was a non-application of mind. However, the petitioner contended that this factual issue was raised before the High Court but not considered in the impugned judgment. The Supreme Court noted that while this contention was recorded in its order issuing notice, it was not agitated before the High Court according to the impugned judgment. Since the petitioner submitted that the contention was indeed raised at the hearing but not noted by the High Court, the Supreme Court permitted the petitioner to withdraw the special leave petition and file an appropriate application before the High Court to address this issue.
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