Charanjit Kaur (Smt.) v. ITO (2021) 88 ITR 414 / 211 TTJ 614/ 201 DTR 185 (Chd.)(Trib.)

S. 148 : Reassessment-Notice-Notice was not served-Approval granted was of mechanical manner-Legal issue-Additional ground was admitted-Reassessment proceedings is quashed. [S. 144, 147, 254(1), 282(1), Civil Procedure Code,1908, Order V rule 12, Order III rule 6]

Tribunal admitted the legal ground and held that on the facts the notice of reassessment was not served on the assessee and the Commissioner has given approval in mechanical manner. The reassessment proceedings is quashed.  Followed, CIT v. Chetan Gupta [2016 382 ITR 613 (Delhi)(HC)  (AY.2010-11)