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ITAT invalidated reassessment proceedings due to procedural defects in approval under s.147/148. The mandatory prior approval for reopening was found mechanical and lacked proper application of mind, being granted without adequate review of reasons to believe. Regarding sale consideration addition, CIT(A)'s finding that land transfer did not occur during relevant assessment year within meaning of s.2(47) was upheld, as AO failed to demonstrate actual transfer. ITAT found no merit in revenue's contentions on both grounds - procedural invalidity of reopening and timing of land transfer. Revenue's appeal dismissed, nullifying reassessment and associated additions.
ITAT invalidated reassessment proceedings due to procedural defects in approval under s.147/148. The mandatory prior approval for reopening was found mechanical and lacked proper application of mind, being granted without adequate review of reasons to believe. Regarding sale consideration addition, CIT(A)'s finding that land transfer did not occur during relevant assessment year within meaning of s.2(47) was upheld, as AO failed to demonstrate actual transfer. ITAT found no merit in revenue's contentions on both grounds - procedural invalidity of reopening and timing of land transfer. Revenue's appeal dismissed, nullifying reassessment and associated additions.
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