https://www.taxtmi.com/highlights?id=63588 Reopening of assessment u/s 147 - recording of satisfaction in mechanical manner - PCIT also mechanically issued permission to reopen the assessment without going into the facts available on record. Even in the Form for seeking approval, in Column 8, the AO records that no return has been filed by the assessee even though factually incorrect and the PCIT did not apply his mind while granting approval as he has simply gone by what is recorded by the AO which is factually wrong. - AT en-us Fri, 20 May 2022 09:01:22 +0530 Fri, 20 May 2022 09:01:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=63588 Reopening of assessment u/s 147 - recording of satisfaction in mechanical manner - PCIT also mechanically issued permission to reopen the assessment without going into the facts available on record. Even in the Form for seeking approval, in Column 8, the AO records that no return has been filed by the assessee even though factually incorrect and the PCIT did not apply his mind while granting approval as he has simply gone by what is recorded by the AO which is factually wrong. - AT Highlights Income Tax Fri, 20 May 2022 09:01:22 +0530 https://www.taxtmi.com/highlights?id=63588