https://www.taxtmi.com/highlights?id=62906 Reopening of assessment u/s 147 - It is also correct that after the assessment order was passed, the Commissioner of Income Tax had commenced revision proceedings under Section 263 of the Act on the very same issue of profit on sale of investment and the revision proceedings were dropped by an order dated 6th March, 2013. Therefore, the same issue cannot form a reason to believe for assessment officer to issue notice under Section 148. In our view, if only this fact has been brought to the notice of the Commissioner who accorded sanction under Section 151, certainly this sanction would not have been granted. - HC en-us Thu, 14 Apr 2022 08:09:18 +0530 Thu, 14 Apr 2022 08:09:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=62906 Reopening of assessment u/s 147 - It is also correct that after the assessment order was passed, the Commissioner of Income Tax had commenced revision proceedings under Section 263 of the Act on the very same issue of profit on sale of investment and the revision proceedings were dropped by an order dated 6th March, 2013. Therefore, the same issue cannot form a reason to believe for assessment officer to issue notice under Section 148. In our view, if only this fact has been brought to the notice of the Commissioner who accorded sanction under Section 151, certainly this sanction would not have been granted. - HC Highlights Income Tax Thu, 14 Apr 2022 08:09:18 +0530 https://www.taxtmi.com/highlights?id=62906