Reassessment proceedings u/s 147 of Income-tax Act, 1961.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... 2 of the said Instruction. 2. The modified Instruction would now read as under:- "Attention is invited to the Board's Instruction No. 120** [F. No. 5/229/69-IT(Inv.)] dated the 27th October, 1969 wherein it was stated that reasons recorded before submitting the proposals for initiating reassessment proceedings should conform to the requirements of section 147 of the Income-tax Act, 1961. A ref....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....so long as his reasons are not different from those of his predecessor. It, would, however, be necessary for the successor Income-tax Officer not to act mechanically as a result of the approval given by the Commissioner/Board on the basis of the predecessor Income-tax Officer's proposal. It is necessary for the successor Income-tax Officer to apply his mind to the issue of initiating reassessment ....