Reassessment initiation was held invalid because the AO...

Reassessment initiation was held invalid because the AO repeatedly re-presented a proposal for sanction under s.151 after initial rejection; the Act confers no power of review on either the AO or the sanctioning authority, rendering the subsequent approval and consequent s.148 proceedings without jurisdiction. The recorded "reasons to believe" were also found unsustainable as the loose papers were misread, contained multiple unrelated names/entities, and lacked any corroborative material linking the assessee to alleged illegal gratification or tender awards by an independent government undertaking; thus the foundational jurisdictional facts were absent. The reopening was quashed and relief granted to the assessee. - HC