https://www.taxtmi.com/caselaws?id=447500 ITAT Surat held that reopening of assessment u/s 147 for bogus purchases after four years was invalid. The AO failed to obtain mandatory sanction from Joint Commissioner as required u/s 151(2) and lacked proper approval. Additionally, notice u/s 148 was issued by ITO Ward-33(2), New Delhi instead of the competent jurisdictional AO at Surat. Since all material was available during original assessment u/s 143(3), the reopening and subsequent notice were held bad-in-law, rendering all subsequent actions ab initio void. Assessee's appeal was allowed. en-us Tue, 26 Dec 2023 00:00:00 +0530 Thu, 28 Dec 2023 08:43:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447500 ITAT Surat held that reopening of assessment u/s 147 for bogus purchases after four years was invalid. The AO failed to obtain mandatory sanction from Joint Commissioner as required u/s 151(2) and lacked proper approval. Additionally, notice u/s 148 was issued by ITO Ward-33(2), New Delhi instead of the competent jurisdictional AO at Surat. Since all material was available during original assessment u/s 143(3), the reopening and subsequent notice were held bad-in-law, rendering all subsequent actions ab initio void. Assessee's appeal was allowed. Case-Laws Income Tax Tue, 26 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447500