TaxTMI 
TaxTMI 
2020 (2) TMI 1727
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....t, however, was subsequently reopened by him on the basis of information received from DDIT(Inv.) Unit-2(2), Kolkata regarding the substantial deposits found to be made in the undisclosed bank account maintained by the assessee with ICICI bank in the name of his proprietary concern M/s. Kalpana Trading. Accordingly, a notice u/s 148 was issued by the AO after recording the reasons. The assessee did not file any return of income in response to the said notice issued by the AO u/s 148. Thereafter, the AO completed the assessment u/s 143(3)/147 of the Act vide an order 26.12.2017 wherein he treated the entries found to be reflected in the bank account of the assessee with ICICI bank as accommodation entries provided by the assessee as entry op....
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....s by applying the rate of 0.5% and according the addition of Rs. 21,20,256/- made by the AO on this issue was restricted by him to Rs. 10,60,128/-. Still aggrieved by the order of the Ld. CIT(A), the assessee has preferred this appeal before the Tribunal. 4. I have heard the arguments of both the sides and also perused the relevant material available on record. In support of the preliminary issue raised by the assessee in this appeal challenging the validity of the assessment made by the AO u/s 143(3)/147 of the Act, the learned counsel for the assessee has invited my attention to the copy of approval given by the Ld. Pr. CIT -8, Kolkata placed at page 55 and 56 of the Paper Book and pointed out that merely a single word "yes" wa....
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....gh Court in the case of PCIT vs. N.C. Cables Ltd. [2017] 391 ITR 11 (Delhi) dated. 11.01.2017 at para 11 states as follows: "11. Section 151 of the Act clearly stipulates that the CIT (A), who is the competent authority to authorize the reassessment notice, has to apply his mind and form an opinion. The mere appending of the expression 'approved' says nothing. It is not as if the CIT (A) has to record elaborate reasons for agreeing with the noting put up. At the same time, satisfaction has to be recorded of the given case which can be reflected in the briefest possible manner. In the present case, the exercise appears to have been ritualistic and formal rather than meaningful, which is the rationale for the safeguard of an approv....