Section 147 of Income Tax Act, 1961—Reassessment — The assessee in its various grounds of appeal has challenged the order of the Ld. CIT(A) in confirming the addition of Rs. 4,25,810/- and has also challenged the validity of proceedings u/s. 147.

Since the assessee has earned capital gain of Rs. 4,39,342/- and claimed the same as long term capital gain exempt from tax, the Assessing Officer held the same to be non genuine and accordingly made addition of Rs. 4,39,342/-.

Held that—Since in the instant case also both the approving authorities have given the approval in a mechanical manner, therefore, in the light of the ratio laid down by the decisions cited (supra) and the other decisions filed in the case law compilation, the reassessment proceedings in my opinion are not in accordance with law. Therefore, the same is liable to be quashed. I, therefore, quash the reassessment proceedings.[MUKESH CHAND GARG VERSUS ITO WARD- 49 (3) NEW DELHI] [2019] 18 ITCD Online (7) [ITAT DELHI]