https://www.taxtmi.com/caselaws?id=457112 Reassessment approval under the Income-tax Act must reflect genuine application of mind to the statutory conditions before sanction is granted. Here, the approval form incorrectly treated the matter as falling under Section 149(1)(b) despite the notice under Section 148A(b) having been issued within three years and the alleged escapement being below the threshold for that provision. The Bombay HC found that both the officer seeking approval and the Principal Commissioner granting it overlooked this inconsistency, making the sanction mechanical and invalid. The order under Section 148A(d) and the notice under Section 148 were therefore quashed and set aside. en-us Fri, 29 Sep 2023 00:00:00 +0530 Fri, 06 Sep 2024 08:22:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=457112 Reassessment approval under the Income-tax Act must reflect genuine application of mind to the statutory conditions before sanction is granted. Here, the approval form incorrectly treated the matter as falling under Section 149(1)(b) despite the notice under Section 148A(b) having been issued within three years and the alleged escapement being below the threshold for that provision. The Bombay HC found that both the officer seeking approval and the Principal Commissioner granting it overlooked this inconsistency, making the sanction mechanical and invalid. The order under Section 148A(d) and the notice under Section 148 were therefore quashed and set aside. Case-Laws Income Tax Fri, 29 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=457112