The Commissioner grants sanction/approval on two separate reassessment notices initiated by the AO on the same date and for the same assessment year, clearly revealing non-application of mind. Further, the subsequent notice fails to mention the earlier approval granted, leading to severe doubts on the application of mind by the Commissioner at the time of grant of approval to the impugned reasons to believe. ((AY. 2009-10)
Kashmir Singh v. ITO (2022) 216 TTJ 523 / 211 DTR 217 (Amritsar)(Trib.)
S. 151 : Reassessment-Sanction for issue of notice-two separate notices-Same assessment year-No application of mind-Reassessment was quashed. [S. 147, 148]