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2020 (5) TMI 507 - AT - Income TaxReopening of assessment u/s 147 - defective approval u/s. 151 - whether approval mechanical and without application of mind? - HELD THAT:- Referring to remarks of the Addl. CIT, Range-55, New Delhi as well as Pr. CIT, Delhi-19, New Delhi, find that the approval granted by both the authorities are mechanical and without application of mind, which are 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 Addl. CIT, Range-55, Delhi as well as Pr. CIT, Delhi-19 for reaching to the satisfaction for granting approval. Thereafter, the AO has mechanically issued notice u/s. 148 Reopening in the case of the assessee for the asstt. Year in dispute is bad in law and deserves to be quashed. See DHARMENDER KUMAR C/O RAJ KUMAR & ASSOCIATES VERSUS ITO, WARD 65 (5) , NEW DELHI [2019 (10) TMI 736 - ITAT DELHI] - Decided in favour of assessee.
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