Mayurbhai Mangaldas Patel. v. ITO (2018) 168 ITD 317 (Ahd) (Trib.)

S. 151 : Reassessment – Sanction for issue of notice -Reassessment proceedings couldn’t be quashed just because AO had obtained prior approval from higher authority [ S. 147, 148 ]

Dismissing the appeal of the assessee the Tribunal held that ; Reassessment proceedings couldn’t be quashed just because AO had obtained prior approval from higher authority .Merely because an even higher authority i.e. Commissioner has also expressed similar satisfaction, does not obliterate satisfaction of appropriate authorities and, thus, reassessment proceedings cannot be quashed on said ground. ( AY. 2005 -06)