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2020 (10) TMI 251 - AT - Income TaxReopening of assessment u/s 147 - Approach of CIT for granting satisfaction for granting approval - HELD THAT:- Approval granted by the Ld. CIT-5, 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 Ld. CIT-5, New Delhi for reaching to the satisfaction for granting approval. AO has mechanically issued notice u/s. 148 - 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. Approval granted by the Ld. CIT-5, New Delhi is a mechanical and without application of mind, which is not valid for initiating the reassessment proceedings issue of notice u/s. 148 and is not in accordance with section 151 thus, the notice issued u/s.148 is invalid and accordingly the reopening in this case is bad in law and therefore, the same is hereby quashed. - Assessee appeal is allowed.
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