https://www.taxtmi.com/caselaws?id=447659 ITAT Mumbai upheld validity of reassessment notice issued under section 148 after four years with PCIT sanction under section 151. Tribunal held that section 151 is procedural law, applicable as per year when reasons were recorded, not assessment year. AO's independent application of mind was found valid based on DGIT investigation report regarding bogus purchases. However, addition under section 69C was restricted to 10% of disputed purchases worth Rs. 10,29,788 from International Trade Agency, as revenue did not doubt sales and complete disallowance was deemed excessive. en-us Fri, 29 Dec 2023 00:00:00 +0530 Mon, 01 Jan 2024 14:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447659 ITAT Mumbai upheld validity of reassessment notice issued under section 148 after four years with PCIT sanction under section 151. Tribunal held that section 151 is procedural law, applicable as per year when reasons were recorded, not assessment year. AO's independent application of mind was found valid based on DGIT investigation report regarding bogus purchases. However, addition under section 69C was restricted to 10% of disputed purchases worth Rs. 10,29,788 from International Trade Agency, as revenue did not doubt sales and complete disallowance was deemed excessive. Case-Laws Income Tax Fri, 29 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447659