https://www.taxtmi.com/caselaws?id=782204 ITAT Kolkata-AT held that the reopening of assessment under sections 147/148 was invalid. The AO recorded reasons based on incorrect facts and without proper application of mind while alleging bogus short-term capital loss entries and making addition under section 68. Further, the approval granted by the PCIT under section 151(2), containing only a mechanical endorsement such as "yes, I am satisfied," was found inadequate, as it did not demonstrate independent satisfaction. Consequently, ITAT quashed the notice issued under section 148 and set aside the reassessment order passed under sections 143(3)/147, along with the related additions. en-us Wed, 19 Nov 2025 00:00:00 +0530 Wed, 26 Nov 2025 08:43:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782204 ITAT Kolkata-AT held that the reopening of assessment under sections 147/148 was invalid. The AO recorded reasons based on incorrect facts and without proper application of mind while alleging bogus short-term capital loss entries and making addition under section 68. Further, the approval granted by the PCIT under section 151(2), containing only a mechanical endorsement such as "yes, I am satisfied," was found inadequate, as it did not demonstrate independent satisfaction. Consequently, ITAT quashed the notice issued under section 148 and set aside the reassessment order passed under sections 143(3)/147, along with the related additions. Case-Laws Income Tax Wed, 19 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782204