https://www.taxtmi.com/caselaws?id=447480 The Gauhati HC upheld reassessment proceedings under Section 147 of the Income Tax Act, 1961. The court held that approval under Section 151 is not mere formality but an important safeguard against arbitrary reopening. The authority for approval varies based on timing - Principal/Chief Commissioner for cases beyond four years, Joint Commissioner for cases within four years. The court ruled that non-communication of entire satisfaction note does not vitiate reassessment proceedings, as furnishing reasons to assessee is not statutorily required. Regarding bogus LTCG exemption denial on penny stocks, the court found sufficient reasons existed to believe income escaped assessment. The plea of Section 151 non-compliance was rejected as it wasn't specifically raised in pleadings. en-us Wed, 20 Dec 2023 00:00:00 +0530 Fri, 01 Mar 2024 14:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447480 The Gauhati HC upheld reassessment proceedings under Section 147 of the Income Tax Act, 1961. The court held that approval under Section 151 is not mere formality but an important safeguard against arbitrary reopening. The authority for approval varies based on timing - Principal/Chief Commissioner for cases beyond four years, Joint Commissioner for cases within four years. The court ruled that non-communication of entire satisfaction note does not vitiate reassessment proceedings, as furnishing reasons to assessee is not statutorily required. Regarding bogus LTCG exemption denial on penny stocks, the court found sufficient reasons existed to believe income escaped assessment. The plea of Section 151 non-compliance was rejected as it wasn't specifically raised in pleadings. Case-Laws Income Tax Wed, 20 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447480