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ITAT held that two distinct reasons to reopen assessment were recorded by the AO and separately transmitted for sanction under s.151; the first online sanction lacked the PCIT's signature and contained forwarding/factual irregularities, while the subsequent manual sanction, issued after the s.148 notice, prevailed. The Tribunal found the "rubber-stamp" allegation unfounded as independent reasons existed, but concluded that because the operative manual approval post-dated the issuance of the s.148 notice, the notice was invalid ab initio. Result: reopening of assessment quashed and the s.148 notice held void, with the manual sanction treated as the valid authorization for reopening (subject to temporal invalidity here).
ITAT held that two distinct reasons to reopen assessment were recorded by the AO and separately transmitted for sanction under s.151; the first online sanction lacked the PCIT's signature and contained forwarding/factual irregularities, while the subsequent manual sanction, issued after the s.148 notice, prevailed. The Tribunal found the "rubber-stamp" allegation unfounded as independent reasons existed, but concluded that because the operative manual approval post-dated the issuance of the s.148 notice, the notice was invalid ab initio. Result: reopening of assessment quashed and the s.148 notice held void, with the manual sanction treated as the valid authorization for reopening (subject to temporal invalidity here).
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