The petitioner challenged the issue of notice on the ground that approval to annexure to the recorded reason was not legible. The petitioner also contended that the recorded reason pertain to other assessee. Two other reasons are signed by successor officer and not the Officer who has issued the notice. Allowing the petition the Court held that the reasons pertain to another assessee and sanction was also not in accordance with law. The notice was quashed. (AY. 2012-13)
Novelty Properties & Investment Pvt. Ltd. v. ACIT (2022) 209 DTR 185 / 325 CTR 373 (Bom.)(HC)
S. 151 : Reassessment-Sanction for issue of notice-Reason recorded was furnished of other assessee-Two further reasons were signed by successor officer and no fresh approval was obtained-Reassessment notice was quashed. [S. 147, 148, Art. 226]