https://www.taxtmi.com/caselaws?id=464924 ITAT Kolkata dismissed the revenue's appeal and upheld the order of CIT(A). It held that for AY 2016-17, where alleged escapement exceeded Rs. 50 lakh, TOLA was inapplicable, so the s.148 notice could not be deemed a s.148A(b) notice, rendering the subsequent s.148A(d), s.148 and s.147 proceedings without jurisdiction. Further, mandatory approval under s.151 was not obtained from the proper authority (PCCIT/CCIT). The reassessment was also invalid as additions were made on grounds not forming the recorded reasons, based on borrowed satisfaction and speculative "potential" cash borrowings. On merits, s.69A addition failed as the assessee was only a borrower, not owner of money. en-us Thu, 17 Apr 2025 00:00:00 +0530 Fri, 21 Nov 2025 11:53:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464924 ITAT Kolkata dismissed the revenue's appeal and upheld the order of CIT(A). It held that for AY 2016-17, where alleged escapement exceeded Rs. 50 lakh, TOLA was inapplicable, so the s.148 notice could not be deemed a s.148A(b) notice, rendering the subsequent s.148A(d), s.148 and s.147 proceedings without jurisdiction. Further, mandatory approval under s.151 was not obtained from the proper authority (PCCIT/CCIT). The reassessment was also invalid as additions were made on grounds not forming the recorded reasons, based on borrowed satisfaction and speculative "potential" cash borrowings. On merits, s.69A addition failed as the assessee was only a borrower, not owner of money. Case-Laws Income Tax Thu, 17 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464924