TaxTMI 
TaxTMI 
2026 (1) TMI 64
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....R is represented on behalf of the revenue. 3. It was submitted by the ld. AR that the assessee is challenging the reopening of the assessment. The assessee has filed a paper book in respect of approvals which reads as follows: It was a submission that a perusal of the approval shows that the approval date by is 28/03/2019, the noting on top of the said page shows that the same was received by the Assessing Officer on 01/04/2019. It was a submission that the notice under Section 148 has been issued to the assessee dated 29/03/2019. It was a submission that as the approval as reached the Assessing Officer only on 01/04/2019, he could not have issued the notice under Section 148 of the Act on 29/03/2019. It was a submission that the fact....
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....esent case clearly shows that the approval granted by the ld. Pr.CIT, admittedly is undated and the satisfaction note is by application of a seal, the fact that the form for approval has been served on the assessee having the seal but not the signature of the ld. Pr.CIT clearly shows that the ld. Pr.CIT has not applied his mind but the seal has already been put. Thus the placing of the seal cannot be said to be a recording of satisfaction of the ld. Pr.CIT. As we find that the satisfaction for the approval for issuance of notice under Section 148 by the ld. Pr.CIT is invalid, we are of the view that the reopening is also invalid and the consequential assessment stands quashed. 6. In the result, this appeal of the assessee stands allowed.....
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....JOINT COMMISSIONER OF INCOME TAX/PRINCIPAL COMMISSIONER OF INCOME TAX 1 Name & Address of the : SGS Real Estates Private Limited Assessee 2 P.A. No./G.I.R.No. : AALCS5217K 3 Status : Co. 4 Ward/Circle/Range : ACIT, Central Circle - 1/Ranchi 5 Assessment Year in respect : 2012-13 of which it is proposed to issue notice u/s.148 6 The quantum of income/loss : Rs.1,14,00,000/- which has escaped assessment 7 Whether the assessment is : No proposed to be made for the first time. If the reply is in the affirmative, please state :- a) Whether any Voluntary : Return had already filed and; b) Whether it is a case of : under assessment, assessment at too low rate, assessment which has been made the subject of excessive relief or a....
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....18 (Shouvik Guha) Principal Commissioner of Income Tax (Central), Patna Document 4 / DDL/JONNY COHETESIORER OF 2 E.4, 102/G.J.K. No. AALCS5219V 3 Status : Co Ward/Circle/Range : ACIT, Central Circle - 1/Ranchi 5 Assessment Year in respect : 2012-13 of which it is proposed to issue notice u/s.148 6 The quantum of income/loss : Rs.1,14,00,000/- which has escaped assessment 7 Whether the assessment is : No proposed to be made for the first time. If the reply is in the affirmative, please state :- a) Whether any Voluntary : Return had already filed and; b) Whether it is a case of under assessment, assessment at too low rate, assessment which has been made the subject of excessive relief or allowing or excessive loss of ....