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2019 (10) TMI 735 - AT - Income TaxReopening of assessment u/s 147 - approval granted by the Ld. Pr. CIT-3, Delhi, New Delhi is a mechanical and without application of mind - HELD THAT:- After perusing the aforesaid remarks of the Pr. CIT-3, Delhi, New Delhi, I find that the approval granted by the Ld. Pr. CIT-3, Delhi, New Delhi is a mechanical and without application of mind, which is not valid for initiating the reassessment proceedings, because from the aforesaid remarks, it is not coming out as to which material; information; documents and which other aspects have been gone through and examined by the Pr. CIT-3, Delhi for reaching to the satisfaction for granting approval. AO has mechanically issued notice u/s. 148 of the Act. Reopening in the case of the assessee for the asstt. Year in dispute is bad in law and deserves to be quashed. Thus initiating the reassessment proceedings by issue of notice u/s. 148 is not in accordance with section 151 of the I.T. Act, 1961, thus, the notice issued u/s. 148 of the Act is invalid and accordingly the reopening in this is bad in law and therefore, the same is hereby quashed. - Decided in favour of assessee.
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