https://www.taxtmi.com/caselaws?id=462830 The ITAT Ahmedabad quashed a reassessment order under Section 143(3) read with Section 147, despite finding valid reasons for reopening. The tribunal acknowledged that the AO had reasonable grounds to believe income escaped assessment due to unexplained cash deposits and non-filing of returns. However, the reassessment failed on procedural grounds. The approval under Section 151 was invalid as it lacked a date, making it impossible to verify whether approval was obtained before issuing the Section 148 notice. Additionally, the Revenue failed to issue the mandatory notice under Section 143(2) after the assessee filed returns in response to the Section 148 notice. Following the SC decision in Hotel Blue Moon, the tribunal held that failure to issue Section 143(2) notice rendered the reassessment invalid. The assessee's appeal was allowed and the reassessment order was quashed. en-us Fri, 17 Jan 2020 00:00:00 +0530 Fri, 18 Jul 2025 23:27:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462830 The ITAT Ahmedabad quashed a reassessment order under Section 143(3) read with Section 147, despite finding valid reasons for reopening. The tribunal acknowledged that the AO had reasonable grounds to believe income escaped assessment due to unexplained cash deposits and non-filing of returns. However, the reassessment failed on procedural grounds. The approval under Section 151 was invalid as it lacked a date, making it impossible to verify whether approval was obtained before issuing the Section 148 notice. Additionally, the Revenue failed to issue the mandatory notice under Section 143(2) after the assessee filed returns in response to the Section 148 notice. Following the SC decision in Hotel Blue Moon, the tribunal held that failure to issue Section 143(2) notice rendered the reassessment invalid. The assessee's appeal was allowed and the reassessment order was quashed. Case-Laws Income Tax Fri, 17 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462830