The ITAT held that the reopening of assessment under section 147 was invalid as the approval letter was improperly issued by an incompetent authority and consolidated for multiple independent assessees without independent satisfaction, violating section 151. Consequently, the issuance of notice under section 148 and subsequent proceedings were quashed. Regarding unexplained investments under section 69, the CIT(A) failed to exercise co-terminus powers to direct further inquiry, leading to a premature rejection of the assessee's evidence; thus, the additions were deleted. Penalty under section 271(1)(c) for non-compliance with notices was also deleted considering the appellant's occupation and genuine reasons for non-compliance. The appeals were allowed, setting aside the reassessment and penalty imposed by the revenue authorities.
The ITAT held that the reopening of assessment under section 147 was invalid as the approval letter was improperly issued by an incompetent authority and consolidated for multiple independent assessees without independent satisfaction, violating section 151. Consequently, the issuance of notice under section 148 and subsequent proceedings were quashed. Regarding unexplained investments under section 69, the CIT(A) failed to exercise co-terminus powers to direct further inquiry, leading to a premature rejection of the assessee's evidence; thus, the additions were deleted. Penalty under section 271(1)(c) for non-compliance with notices was also deleted considering the appellant's occupation and genuine reasons for non-compliance. The appeals were allowed, setting aside the reassessment and penalty imposed by the revenue authorities.
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