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| The Tax Publishers2019 TaxPub(DT) 8268 (Del-Trib) INCOME TAX ACT, 1961
Section 151
Jt. CIT had given approval to reopening of assessment in a mechanical manner without due application of mind by mentioning only 'Yes' in Column No. 12 of the Format for recording the reasons for initiating proceedings under section 147 and for obtaining the approval of the Addl./Jt. CIT, CIT and therefore, reassessment proceedings were invalid.
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Reassessment - Validity - Mechanical approval granted by Jt. CIT under section 151 -
Assessee challenged validity of reassessment framed under section 147 on the ground of mechanical approval granted by Jt. CIT under section 151 for initiation of reassessment proceedings.Held: Jt. CIT had given approval to reopening of assessment in a mechanical manner without due application of mind by mentioning only 'Yes' in Column No. 12 of the Format for recording the reasons for initiating proceedings under section 147 and for obtaining the approval of the Addl./Jt. CIT, CIT and therefore, reassessment proceedings were invalid.
Followed:Gopal Chand Manudhra & Sons, Damyanti Mundhra, Ramdev Mundhra, Shriya Devi Mundhra & Gopal Chand Mundhra v. ITO [ITA No. 1375, 1721, 1722, 1523-1524/Del/2019] : 2019 TaxPub(DT) 5436 (Del-Trib).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
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