Court Examines Validity of Reopening Tax Assessment u/ss 147 and 151; Assessee's Approval Challenge Questioned.

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....Validity of reopening of assessment u/s 147 - approval u/s.151 - No wonder that the assessee’s claim before the ld. CIT(A) is ambivalent, stating that the proceedings had been initiated without obtaining of Approval or the Approval is not in accordance with law, clearly indicating of the assessee being not aware of or, in the least, not sure of the actual facts of the case. Rather, the assessee’s request dated 11/11/2016 to the AO cannot be regarded as a valid request in law as the assessee had till then admittedly not furnished any return in response to the notice u/s. 148(1), which was filed only on 18/11/2016. - AT....