Reassessment Invalid: Notice Issued Without Commissioner Approval u/s 147, Rendering Section 148 Reopening Flawed.
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....Reopening of assessment u/s 147 - approval of the concerned CIT after date of issuance of notice - since notice has been issued prior to the approval. Thus, reopening u/s 148 is without the approval of the designated authority and as such reassessment itself is bad and without any jurisdiction....
TaxTMI