Allowing the petition the Court held that reasons placed for consideration before Joint Commissioner to seek approval and reasons submitted for approval as appropriate reasons for reopening is contrary. Reassessment order is set aside and quashed. (AY. 2017-18)
Floyd Filandro Linhares v. ITO (2024) 166 taxmann.com 125 / (2025) 473 ITR 587 (Bom)(HC)
S. 147 : Reassessment-Recorded reasons-Sanction-Reasons placed for consideration before Joint Commissioner to seek approval-Reasons submitted for approval as appropriate reasons for reopening is contrary-Reassessment order is set aside and quashed.[S. 148, 151, Art. 226]
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