https://www.taxtmi.com/caselaws?id=441540 Validity of reopening under section 147 was examined on whether the approval under the reassessment scheme (section 151) constituted a valid sanction. The court found no valid sanction and concluded both the officer seeking approval and the approving authority failed to apply their minds to material facts, rendering the approval and notice ultravires. For that reason the notice issued under the reassessment procedure and the order under the reassessment safeguard provision were quashed, resulting in a decision for the assessee. en-us Tue, 01 Aug 2023 00:00:00 +0530 Mon, 04 May 2026 10:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=441540 Validity of reopening under section 147 was examined on whether the approval under the reassessment scheme (section 151) constituted a valid sanction. The court found no valid sanction and concluded both the officer seeking approval and the approving authority failed to apply their minds to material facts, rendering the approval and notice ultravires. For that reason the notice issued under the reassessment procedure and the order under the reassessment safeguard provision were quashed, resulting in a decision for the assessee. Case-Laws Income Tax Tue, 01 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=441540