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2019 (1) TMI 941 - AT - Income TaxReopening of assessment - reasons recorded and satisfaction accorded is not within the meaning of section 151 - addition u/s 68 - reasons recorded and satisfaction accorded is not within the meaning of section 151 - Held that:- The satisfaction recorded and approval granted by the Addl. CIT, Range-6/Competent Authority is a mechanical and action has been taken mechanically because on perusing the reasons recorded, which demonstrates that Addl. CIT Range-6 has written “Approved” which establishes that the authority has not recorded proper satisfaction/approval, before issue of notice u/s. 148. AO has mechanically issued notice u/s. 148 of the Act, on the basis of information allegedly received by him from the DIT (Inv.), New Delhi. We are of the considered view that the reopening in the case of the assessee for the asstt. Year in dispute is bad in law and deserves to be quashed. Issue of notice u/s. 148 of the I.T. Act, 1961 is not in accordance with section 151 of the I.T. Act, 1961, hence, the reopening in the case of the assessee for the asstt. Year in dispute is bad in law and therefore, the same is hereby quashed - decided in favour of assessee.
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