Allowing the appeal the Tribunal held that the reason for reassessment was referred as per section 147(b) cannot be accepted as a typographical human error which was curable under section 292B of the Act. The orders of the authorities below were to be set aside, the reopening of the assessment in both the assessment years under appeals were to be quashed and all additions were deleted. Followed Kalpana Shantilal Haria v. ACIT (2017) 100 CCH 165 (Bom)(HC) (AY. 2009-10, 2010-11)
Madhu Apartment Private Limited v. ITO (2021)86 ITR 317 (Delhi) (Trib.)
S. 147 : Reassessment-Mentioning of wrong section 147(b)-Not curable defects-Reassessment was quashed as bad in law [S. 148, 292B]