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ITAT allowed the assessee's appeal, invalidating the reassessment proceedings due to procedural defects. The Pr. CIT's approval for reopening assessment under Section 148 was deemed invalid, as the use of "may be reopened" indicated a casual approach without proper application of mind. The tribunal found no independent satisfaction by the competent authority, and the approval failed to meet the statutory requirements of Section 151. The notice was issued prematurely, without adhering to legal provisions, rendering the reassessment proceedings technically unsustainable. Consequently, the reopening of assessment was quashed on procedural grounds.
ITAT allowed the assessee's appeal, invalidating the reassessment proceedings due to procedural defects. The Pr. CIT's approval for reopening assessment under Section 148 was deemed invalid, as the use of "may be reopened" indicated a casual approach without proper application of mind. The tribunal found no independent satisfaction by the competent authority, and the approval failed to meet the statutory requirements of Section 151. The notice was issued prematurely, without adhering to legal provisions, rendering the reassessment proceedings technically unsustainable. Consequently, the reopening of assessment was quashed on procedural grounds.
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