https://www.taxtmi.com/caselaws?id=451106 The Madras HC quashed reassessment proceedings under Section 148A(d) and Section 148 notices for multiple assessment years. The petitioner failed to deduct withholding tax assuming a favorable AAR ruling, which was declined. The court found the reopening was based on erroneous factual foundation as the assessing officer ignored the assessee's objections and failed to apply mind to presented material. Additionally, for AYs 2016-2017 and 2017-2018, approval was granted by Chief Commissioner instead of Principal Chief Commissioner as required under Section 151(ii) when more than three years had elapsed. The reassessment proceedings were held vitiated on both grounds. en-us Tue, 27 Feb 2024 00:00:00 +0530 Fri, 12 Jul 2024 11:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=451106 The Madras HC quashed reassessment proceedings under Section 148A(d) and Section 148 notices for multiple assessment years. The petitioner failed to deduct withholding tax assuming a favorable AAR ruling, which was declined. The court found the reopening was based on erroneous factual foundation as the assessing officer ignored the assessee's objections and failed to apply mind to presented material. Additionally, for AYs 2016-2017 and 2017-2018, approval was granted by Chief Commissioner instead of Principal Chief Commissioner as required under Section 151(ii) when more than three years had elapsed. The reassessment proceedings were held vitiated on both grounds. Case-Laws Income Tax Tue, 27 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=451106