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2019 (10) TMI 857 - ITAT DELHIValidity of the reassessment proceedings in absence of proper approval given u/s 151 - HELD THAT:- A perusal of the copy of approval given u/s 151 shows that the Addl. CIT, while giving approval has simply mentioned: “Yes. I am satisfied that it is a fit case for reopening of assessment u/s 148.” Similarly, the PCIT, while giving approval has also simply mentioned: “I am satisfied that it is a fit case for issue of notice u/s 148 of the IT Act.” From the above, it is clear that none of the supervisory authorities have applied their mind. In the instant case, both the superior authorities have merely given their approval in a mechanical manner without independent application of mind, therefore, respectfully following the decision of the jurisdictional High Court in the case of N.C. Cables [2017 (1) TMI 1036 - DELHI HIGH COURT] I hold that the reassessment proceedings are bad in law. Appeal filed by the assessee is allowed.
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