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2019 (10) TMI 398 - AT - Income TaxValidity of proceedings u/s. 147 - basis of report of the investigation wing of the department, reopened the assessment - Addition on account of client code modification through broker which has been upheld by the CIT(A) - HELD THAT:- A perusal of the proforma for approval to issue of notice u/s. 148, copy of which is placed at page 12 of the paper book shows that as per clause 12 of the proforma, the PCIT while giving approval has simply mentioned “satisfied”. Similarly as per clause 11, the Addl. CIT has simply mentioned “Yes”, it is a fit case to issue notice u/s. 148 of the IT Act, 1961. As decided in M/S N.C. CABLES LTD. [2017 (1) TMI 1036 - DELHI HIGH COURT] mere appending of the expression 'approved' says nothing. It is not as if the CIT (A) 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 as both the approving authorities have given the approval in a mechanical manner, the reassessment proceedings are not in accordance with law Addition on account of client code modification to be deleted as relying on PAT COMMODITY SERVICES PVT. LTD. [2019 (2) TMI 720 - BOMBAY HIGH COURT] - Decided in favour of assessee.
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