Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2021 (3) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2021 (3) TMI 670 - AT - Income TaxReopening of assessment u/s 147 - Assessee argued that PR. CIT had given a mechanical approval for reopening the assessment, he simply stated that he was satisfied, however no reasons were recorded for his satisfaction - HELD THAT:- From the reading of approval, it is clear that the Ld. Pr. CIT recorded satisfaction in the mechanical manner, without application of mind to accord sanction for issuing notice under section 148 of the Act. As relying on M/S. S. GOYANKA LIME AND CHEMICAL LTD. [2015 (12) TMI 1334 - SC ORDER] reopening under section 148 of the Act on the basis of mechanical approval without applying the mind by the Ld. Pr.CIT was not valid. Therefore, in the present case, the reopening of the assessment on the basis of notice under section 148 of the Act is quashed. Decided in favour of the assessee
|