https://www.taxtmi.com/caselaws?id=784376 Reassessment under s.147 was challenged for want of proper sanction under s.151. The ITAT held that for AY 2016-17, where reopening was within four years, sanction by the Addl. CIT was legally sufficient under the then-prevailing s.151; the post-01.04.2021 amendment requiring PCIT approval was inapplicable. The challenge to assumption of jurisdiction was rejected and the grounds were dismissed. Additions treating bank deposits as unexplained money u/s 69 were remanded because the authorities failed to verify the claim that deposits comprised professional receipts, earlier withdrawals, third-party funds, and loans; the issue was restored to the AO for fresh decision. Notional rent on multiple properties was remanded: sold/self-used properties and those already yielding disclosed rent could not be further loaded, and for remaining properties ALV was to be computed on municipal circle rates with s.24 deduction. LTCG computation was remanded for verification of acquisition/improvement costs and evidence. en-us Wed, 31 Dec 2025 00:00:00 +0530 Sat, 03 Jan 2026 08:03:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784376 Reassessment under s.147 was challenged for want of proper sanction under s.151. The ITAT held that for AY 2016-17, where reopening was within four years, sanction by the Addl. CIT was legally sufficient under the then-prevailing s.151; the post-01.04.2021 amendment requiring PCIT approval was inapplicable. The challenge to assumption of jurisdiction was rejected and the grounds were dismissed. Additions treating bank deposits as unexplained money u/s 69 were remanded because the authorities failed to verify the claim that deposits comprised professional receipts, earlier withdrawals, third-party funds, and loans; the issue was restored to the AO for fresh decision. Notional rent on multiple properties was remanded: sold/self-used properties and those already yielding disclosed rent could not be further loaded, and for remaining properties ALV was to be computed on municipal circle rates with s.24 deduction. LTCG computation was remanded for verification of acquisition/improvement costs and evidence. Case-Laws Income Tax Wed, 31 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784376