Reopening of assessment under notice u/s.148 was invalid because...

Reopening of assessment under notice u/s.148 was invalid because the AO did not satisfy the mandatory conditions for issuing a notice beyond three years, and the reasons failed to establish escaped income exceeding the statutory threshold tied to assets/expenditure or book entries; outcome: notice and consequent assessment quashed. Approval by the prescribed authority under the sanction provision was held mechanical and without independent verification of seized material, lacking application of mind; outcome: sanction invalidated and reinforcement of notice invalidity. Search-origin evidence seized from a third party laptop was not treated as sufficient to justify reopening when statutory conditions were unmet.

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