COURT: | ITAT Delhi |
CORAM: | Diva Singh (JM), Sudhakar Reddy (AM) |
SECTION(S): | 147, 151 |
GENRE: | Domestic Tax |
CATCH WORDS: | Reopening, sanction |
COUNSEL: | Rakesh Kumar Khiwani |
DATE: | November 14, 2014 (Date of pronouncement) |
DATE: | December 2, 2014 (Date of publication) |
AY: | 2000-01 |
FILE: | Click here to view full post with file download link |
CITATION: | |
S. 147/ 151: Reopening mechanically on the basis of material received from another AO is bad. Merely noting "approved" without recording satisfaction is bad |
(i) A perusal of the above demonstrates that the AO has not applied his mind so as to come to an independent conclusion that he has reason to believe that the income has escaped assessment during the year. A mere …
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