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ITAT held that the reopening of assessments under Section 148 was valid. The CIT had applied his mind during approval under Section 151, being fully aware of case facts from prior proceedings under Section 264. The earlier assessments under Section 153C were annulled, rendering previous findings irrelevant. Consequential reassessment proceedings were not time-barred but addressed void proceedings. The administrative revision differed from appellate review, and the approval was not mechanical. The tribunal distinguished prior case laws and affirmed the legitimacy of initiating remedial assessment proceedings consistent with legal principles.
ITAT held that the reopening of assessments under Section 148 was valid. The CIT had applied his mind during approval under Section 151, being fully aware of case facts from prior proceedings under Section 264. The earlier assessments under Section 153C were annulled, rendering previous findings irrelevant. Consequential reassessment proceedings were not time-barred but addressed void proceedings. The administrative revision differed from appellate review, and the approval was not mechanical. The tribunal distinguished prior case laws and affirmed the legitimacy of initiating remedial assessment proceedings consistent with legal principles.
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