TaxTMI 
TaxTMI 
2025 (7) TMI 1117
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....essee has taken the additional ground of appeal in the following manner: "1. On the facts of the case and in law, the notice u/s 148 issued in this case is bad-in-law, without jurisdiction and barred by limitation and, therefore, the said notice and assessment order passed is liable to be quashed. 2. On the facts of the case and in law, the reassessment proceedings initiated are contrary to provisions of section 147 to section 151 of the Act and therefore, the assessment order passed is liable to be quashed. 3. On the facts and circumstances of the case and in law, the assessment order passed by the assessing officer is liable to be quashed as statutory notice u/s 143(2) of the Income Tax Act, 1961 has not been issued." 3. It is the ....
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....on 151 of the Act granted by the PCIT is evidently mechanical in nature as also submitted by him and a copy of the approval letter dated 28.03.2019 has duly been furnished before us. In this respect he has drawn our attention to the last page of the approval where the PCIT notes "Yes I am satisfied on the reasons recorded by the AO that it is a fit case for issue notice under Section 148 of the Act". According to the Ld. AR the same, is nothing but a mechanical approval without application of mind in the same therefore, not valid for initiating the reassessment proceeding. No material, information and/or documents are found to have been found gone through and further examined by the said authority is also evident from such noting made by th....
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....r reopening of assessment under Section 148 of the Act. He, therefore, relying upon the orders passed by the authorities below. 8. We have heard the rival contention made by the respective parties and perused the relevant material available on record. Having regard to the facts and circumstances of the matter, we have carefully gone through the entire records specially the Assessment Order, the Appellate Order, the reasons/satisfaction/approval recorded for issuance of notice under Section 148 of the Act. Upon perusal of the proforma under Section 151 of the Act dated 28.03.2019 particularly the last page of the said proforma wherein the noting made by the Ld. PCIT to this effect "Yes I am satisfied on the reasons recorded by the AO that i....