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2018 (6) TMI 693 - ITAT DELHI
Initiation of proceedings u/s 147 - approval/sanction given by the Pr. CIT without recording satisfaction - Held that:- Approval of Pr.CIT was sought before initiating the proceedings u/s 147 and approval of CIT was given without applied his mind while giving the approval for reopening the assessment - hence following the judicial pronouncements in case of ITO vs. N.C. Cables Ltd. [2014 (11) TMI 593 - ITAT DELHI] and by keeping in view that the approval/sanction given by the Pr. CIT without recording satisfaction, we are of the view that the reopening in the present case is not sustainable - hence reopening u/s 147 of the Act by issuing the notice u/s 148 of the Act on the basis of mechanical approval by the Pr. CIT without recording satisfaction on the objective material is quashed - Decided in favor of assessee.