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The ITAT held that the reopening of assessment under section 147 was invalid due to the absence of valid sanction under section 151. The Pr.CIT's approval was mechanical, evidenced by a standard proforma bearing only a signature without a date or specific reasons, thereby failing to constitute proper authorization. Additionally, the Assessing Officer did not furnish the assessee with the reasons relied upon for reopening, violating procedural requirements. Consequently, the reassessment proceedings were quashed as being contrary to the provisions of section 151, affirming that mechanical or non-specific sanctions and non-communication of reasons to the assessee vitiate the reopening process.
The ITAT held that the reopening of assessment under section 147 was invalid due to the absence of valid sanction under section 151. The Pr.CIT's approval was mechanical, evidenced by a standard proforma bearing only a signature without a date or specific reasons, thereby failing to constitute proper authorization. Additionally, the Assessing Officer did not furnish the assessee with the reasons relied upon for reopening, violating procedural requirements. Consequently, the reassessment proceedings were quashed as being contrary to the provisions of section 151, affirming that mechanical or non-specific sanctions and non-communication of reasons to the assessee vitiate the reopening process.
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