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    <title>2026 (6) TMI 1188 - ITAT AGRA</title>
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    <description>Approval under section 151 for issuance of notice under section 148 was held invalid where the sanctioning authority gave only a bare endorsement that income had escaped assessment and that it was a fit case for reopening. The recording did not show independent consideration of the Assessing Officer&#039;s material or discernible satisfaction by the approving authority, so the jurisdictional safeguard was not met. As a result, the reassessment proceedings based on the reopening notice were unsustainable and were quashed in favour of the assessee.</description>
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      <description>Approval under section 151 for issuance of notice under section 148 was held invalid where the sanctioning authority gave only a bare endorsement that income had escaped assessment and that it was a fit case for reopening. The recording did not show independent consideration of the Assessing Officer&#039;s material or discernible satisfaction by the approving authority, so the jurisdictional safeguard was not met. As a result, the reassessment proceedings based on the reopening notice were unsustainable and were quashed in favour of the assessee.</description>
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