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ITAT Mumbai: Dual Section 151 Approval and Incomplete Reasons Nullify Reassessment

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Summary

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  • The ITAT Mumbai has invalidated the reassessment for AY 2007-08 against Bharti Axa Life Insurance Company Ltd., citing dual Section 151 approvals as a jurisdictional defect.
  • The Tribunal found that the Revenue failed to provide complete reasons for reopening the assessment, which did not establish a failure to disclose material facts.
  • It emphasized that approval must come solely from the Principal Commissioner of Income Tax (PCIT) for cases beyond four years, dismissing the Additional CIT's involvement.
  • This ruling could significantly impact future reassessments, emphasizing strict adherence to procedural requirements in tax law.

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