COURT: | ITAT Delhi |
CORAM: | Rajpal Yadav (JM), Sudhakar Reddy (AM) |
SECTION(S): | 147, 151 |
GENRE: | Domestic Tax |
CATCH WORDS: | Reopening, sanction |
COUNSEL: | Ashwani Taneja, Dr. Rakesh Gupta |
DATE: | October 22, 2014 (Date of pronouncement) |
DATE: | November 7, 2014 (Date of publication) |
AY: | 2001-02 |
FILE: | Click here to view full post with file download link |
CITATION: | |
S. 147/ 151: Sanction by the CIT with word "approved" without recording satisfaction note renders reopening invalid |
(i) A simple reading of the provisions of Sec. 151(1) with the proviso clearly show that no such notice shall be issued unless the Commissioner is satisfied on the reasons recorded by the AO that it is a fit case …
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