Dismissing the petition the Court held that, reasons to believe have been recorded in meticulous details by the AO. Approval was obtained before issue of notice. Objections of the assessee were dealt with on a point to point basis, there is no infirmity in the reassessment proceedings. Accordingly notice of reassessment is held to be valid in law. (AY. 2012-13)
Deepak Gupta v. ACIT (2020) 422 ITR 92/ 186 DTR 250 / 303 CTR 34/ 275 Taxman 338 (All.) (HC)
S. 147 : Reassessment–With in four years-Tax frauds-Reasons to believe have been recorded in meticulous details by the AO-Approval was obtained before issue of notice-Notice of reassessment is held to be valid in law. [S. 148, 151]