Section 147 Challenge: Reopening Assessments Without Proper Approval for Section 148 Notices Raises Concerns Over Mechanical Error Admissions.

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....Reopening of assessment u/s 147 - validity of reasons to believe - undisclosed profit - No approval sought from the Additional Commissioner/Commissioner of Income­tax for issuance of notice u/s 148 - The impugned order rejecting the objections, the Assessing Officer has recorded that the mistake has happened in mostly all the cases reopened during the year because the cases were reopened on the information based and also of non­filers which depicts that the Assessing Officer has mechanically recorded the reasons without properly appreciating the facts of the case. - HC....