The Tribunal held that reassessment proceedings were invalid where the approval granted by the Principal CIT did not correspond with the reasons recorded by the Assessing Officer, omitted approval for major issues forming the basis of reopening and reflected no independent application of mind. Mere search action does not automatically justify reopening in the absence of material indicating escapement of income. Accordingly, the notice under section 148 and the consequential assessment were quashed (AY. 2018-19, to 2020-21)
Rosha Alloys (P.) Ltd. v. DCIT (2025) 238 TTJ 357 / 127 ITR 76 / 175 taxmann.com 622 (Chd.)(Trib.).
S. 151: Reassessment-Sanction for issue of notice-Notice under section 148 invalid where approval under section 151 is mechanical and inconsistent with reasons recorded [S. 148, 148A(b), 148A(d)]
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