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2019 (4) TMI 1787 - AT - Income TaxReopening of assessment u/s 147 - without recording valid reasons and without obtaining valid approval - HELD THAT:- Approval was granted by the Pr. CIT, Faridabad by noting “approved” shows that the approval was given in a mechanical manner without recording proper satisfaction after due application of mind. The Hon’ble Delhi High Court in the case of Pr. CIT Vs N. C. Cables Ltd. [2017 (1) TMI 1036 - DELHI HIGH COURT] has held that mere appending of the expression “approved” says noting. It is not as if the CIT has to record elaborate reasons for agreeing with the noting put up. At the same time, satisfaction has to be recorded of the given case which can be reflected in the briefest possible manner. In the present case, the exercise appears to have been ritualistic and formal rather than meaningful, which is the rationale for the safeguard of an approval by a higher ranking officer. For these reasons, the Court is satisfied that the findings by the ITAT cannot be distributed. Quash the impugned reassessment order and allow the grounds of appeal of the assessee.
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