https://www.taxtmi.com/caselaws?id=306950 A reassessment founded on defective reopening can be questioned in collateral proceedings against a section 263 revision order. The Tribunal found that, although sanction under section 151 had been obtained, reopening failed because the reasons recorded and the reasons communicated to the assessee were not the same, breaching the mandatory requirement to record and disclose the true reasons before reassessment. As the reassessment itself was invalid, the revision order premised on it could not survive and was quashed in favour of the assessee. en-us Thu, 18 Aug 2022 00:00:00 +0530 Thu, 09 Mar 2023 00:00:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306950 A reassessment founded on defective reopening can be questioned in collateral proceedings against a section 263 revision order. The Tribunal found that, although sanction under section 151 had been obtained, reopening failed because the reasons recorded and the reasons communicated to the assessee were not the same, breaching the mandatory requirement to record and disclose the true reasons before reassessment. As the reassessment itself was invalid, the revision order premised on it could not survive and was quashed in favour of the assessee. Case-Laws Income Tax Thu, 18 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306950