In view of the above, it is clear that initiation of reassessment proceedings as well as approval/sanction of Addl. CIT u/s 147/148 of the Act are invalid, illegal and against the provisions of law.
Sec. 147 & 148 of Income Tax Act, 1961—Reassessment— It is well settled law that validity of reassessment proceedings have to be determined with reference to the reasons recorded for reopening of the assessment - Initiation of reassessment proceedings as well as approval/sanction of Addl. CIT u/s 147/148 are invalid, illegal and against the provisions of law as the AO clearly recorded wrong facts in the reasons for reopening of the assessment and did not apply his independent mind to the information received from Investigation Wing - VIMALCHAND M. JAIN V/s ITO - [2019] 75 ITR (TRIB) 059 (ITAT-SURAT)
In view of the above, it is clear that initiation of reassessment proceedings as well as approval/sanction of Addl. CIT u/s 147/148 of the Act are invalid, illegal and against the provisions of law.
Sec. 147 & 148 of Income Tax Act, 1961—Reassessment— It is well settled law that validity of reassessment proceedings have to be determined with reference to the reasons recorded for reopening of the assessment - Initiation of reassessment proceedings as well as approval/sanction of Addl. CIT u/s 147/148 are invalid, illegal and against the provisions of law as the AO clearly recorded wrong facts in the reasons for reopening of the assessment and did not apply his independent mind to the information received from Investigation Wing - VIMALCHAND M. JAIN V/s ITO - [2019] 75 ITR (TRIB) 059 (ITAT-SURAT)