Sagar Bullion Pvt. Ltd. v. UOI (2022) 324 ITR 146 / 209 DTR 281 (Bom.)(HC)

S. 151 : Reassessment-Sanction-After the expiry of four years-Sanction was given mechanically-Without application of mind-Reason recorded stated that the assessment was completed u/s 143(1), whereas the assessment was u/s. 143(3)-Business of jewellery-Reason stated that failure to disclose salary-Reassessment notice was quashed. [S. 147, 148, Art. 226]

The assessment was completed u/s. 143(3) of the Act. The reassessment notice was issued after expiry of four years. In the recorded reasons it was stated that stated that the assessment was completed u/s 143(1), whereas the assessment was u/s 143(3). Assessee is in the business of jewellery  whereas in the recorded reason it was  that failure to disclose salary. On writ the High Court quashed the reassessment notice on the ground that sanction was given mechanically without application of mind.  (AY. 2012-13)