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2023 (7) TMI 852 - ITAT DELHIReopening of assessment u/s 147 - validity of granting approval u/s. 151 - mandation of independent application of mind before granting approval - HELD THAT:- PCIT only mentioned approved in column no 14 - PCIT has not recorded proper satisfaction and granted approval without application of mind in a mechanical manner which is not satisfying the mandatory requirement of provision of sec 151 - Therefore we are in agreement with the conclusion drawn by the ld. CIT(A) that the superior authorities have merely given their approval in a mechanical manner without independent application of mind, therefore, respectfully following the decision of N C Cables [2017 (1) TMI 1036 - DELHI HIGH COURT] we hold that the reassessment proceedings are bad in law. Decided against revenue.
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