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        Case ID :
        Income Tax

        Absence of reasons in approval order u/s 151 for reopening...

        Reopening assessment invalid due to lack of reasons; 'approved' alone insufficient. Approval not a ritual.

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                Absence of reasons in approval order u/s 151 for reopening assessment u/s 148 renders it invalid. Mere appending of word "approved" without recording satisfaction after application of mind is insufficient. Approval is a safeguard, not a mere ritual, and reasons linking material to conclusion are necessary per Supreme Court's decision in M.L. Capoor's case. Principal Chief Commissioner's grant of approval in printed format without reasons fails to fulfil requirement of Section 151. Mere use of "approval" without independent application of mind cannot be considered valid approval.
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