Reopening of assessment under section 147 was quashed because the Assessing Officer lacked tangible information to form a belief that income had escaped assessment; the Tribunal found the AO had misread binding precedent treating amounts under Section 28 of the Land Acquisition Act as accretions to land value (compensation) rather than ordinary 'income from other sources'. The Tribunal also upheld the sanction notation by the Joint Commissioner as valid despite concise wording, finding no absence of application of mind. Result: sanction valid but reopening invalid; appeal allowed.
Reopening of assessment under section 147 was quashed because the Assessing Officer lacked tangible information to form a belief that income had escaped assessment; the Tribunal found the AO had misread binding precedent treating amounts under Section 28 of the Land Acquisition Act as accretions to land value (compensation) rather than ordinary 'income from other sources'. The Tribunal also upheld the sanction notation by the Joint Commissioner as valid despite concise wording, finding no absence of application of mind. Result: sanction valid but reopening invalid; appeal allowed.
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