9911796707
TMI Blog2015 (5) TMI 217X X X X Extracts X X X X X X X X Extracts X X X X ..... As common questions of law and fact are involved in all these appeals filed under section 260-A of the Income Tax Act, 1961 (hereinafter referred to as the „Act‟), all the appeals are being decided by this common order. 2- Challenge in all these appeals are made to concurrent orders passed by the Commissioner (Appeals) and the Income Tax Appellate Tribunal, Jabalpur in the matter of q ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... reason recorded by the Joint Commissioner of Income Tax, for according sanction, it only stated that „I am Satisfied‟. As this action for sanction was without application of mind and as this was done in a mechanical manner, following the law laid down in the case of Arjun Singh Vs. Assistant Director of Income Tax (MP), reported in [2000] 246 ITR 363, the Commissioner quashed the notic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Tax (Central) - I, New Delhi Vs. Vatika Township (P) Limited, (SC) 2014 ITL 833, Shri Sanjay Lal - learned counsel for the appellants, prays for interference into the matter. 6- However, Shri L.L. Sharma - learned counsel for the respondents, placed reliance on another judgment of the Gujarat High Court in the case of Cargo Clearing Agency (Gujarat) Vs. Joint Commissioner of Income Tax, (2008) 30 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e on the format "Yes, I am satisfied" which indicates as if he was to sign only on the dotted line. Even otherwise also, the exercise is shown to have been performed in less than 24 hours of time which also goes to indicate that the Commissioner did not apply his mind at all while granting sanction. The satisfaction has to be with objectivity on objective material." 8- If the case in hand is anal ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
