Reassessment Approval Flaws: Court Criticizes Inadequate Evaluation by Tax Officers in Income Tax Act Section 147 Case.

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....Reopening of assessment u/s 147 - Whether the PCIT applied his mind while granting approval? - Senior officers like ACIT and PCIT are expected to apply their minds to such requests and, only after that, approve the initiation of reassessment proceedings. Several pitfalls that the Court's notice can be avoided if the concerned authorities were to look closely at the request made for re-opening. Clearly, in SIPL’s case, these aspects were not examined by the concerned AO or by the ACIT/PCIT. - HC....