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2020 (3) TMI 956 - AT - Income TaxValadity of Reopening of assessment u/s 147 - AO not applying his mind and without getting the approval of the competent authority - recording satisfaction in mechanical manner - HELD THAT:- CIT is required to apply his mind to the proposal put up to him for approval in the light to the material relied upon by the AO. The said power cannot be exercised casually and in a routine manner. We are constrained to observe that in the present case, there has been no application of mind by the Addl. CIT before granting the approval. CIT is required to apply his mind to the proposal put up to him for approval in the light to eh material relied upon by the AO. The said power cannot be exercised casually and in a routine manner. We are constrained to observe that in the present case, there has been no application of mind by the Addl. CIT before granting the approval. - Decided in favour of assessee.
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