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of <h1>Reassessment quashed where prescribed authority's s.151 approval was mere mechanical 'yes, I am satisfied' endorsement</h1> <h3>Subhash Chand Versus Income-tax Officer, Ward-38 (5), Delhi</h3> Subhash Chand Versus Income-tax Officer, Ward-38 (5), Delhi - TMI Appeal against National Faceless Appeal Centre (NFAC) order ITBA/NFAC/S/250/2023-24/1053591413(1) dated 07.06.2024 (proceedings under section 147 read with section 144 of the Income-tax Act, 1961) challenges validity of the reopening. The prescribed authority's section 151 approval dated 28.03.2017 to the Assessing Officer's reopening reasons records a one-line endorsement: 'yes. I am satisfied.' Relying on PCIT v. Goyanka Lime & Chemical Ltd. [2015] 64 taxmann.com 313 (SC), the Tribunal treats such a mechanical approval as unsustainable in law and quashes the impugned reopening/assessment. Because the section 151 approval was the clinching factual basis for reopening, all other pleadings were rendered academic. The appeal is allowed and the assessment under the reopened proceedings is set aside; order pronounced in open court on 09.01.2025.
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