TMI Blog2017 (3) TMI 1860X X X X Extracts X X X X X X X X Extracts X X X X ..... r (herein Addl. DIT) is required to apply his mind to the proposal put to him for approval in the light of the material relied on by the AO; that the said power cannot be exercised casually and in a routine manner. In that case, as in the present one, the Addl. Commissioner had stated: Yes it is a fit case for issue of notice u/s 148 . The reassessment proceedings were held to be invalid. Thus ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... case for action under sections 147/148 of the IT Act ; that the sanction was applied for and obtained, and the notice (APB-16) u/s 148 of the Act was prepared on 25.03.2014 itself, i.e., all on the same day; that this further shows that there was no application of mind on the issue; that the Addl. DIT is required to apply his mind to the proposal put to him for approval in the light of the materia ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... was also issued on 25.03.2014. 6. The ld. CIT(A) has observed (impugned order page 8, para 4.3, last sentence) that: the Range Head while giving approval has applied his mind, as he has given his approval based on the facts as presented by the AO . 7. In this regard, as rightly contended, in United Electrical (supra) (APB-85- 90) it has been held that the Commissioner (herein Addl. DIT) ..... X X X X Extracts X X X X X X X X Extracts X X X X
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