Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Reopening of assessment was held invalid where the PCIT's approval consisted only of the terse statement "yes, I am satisfied" without recorded reasons; such mechanical approval fails the requirement that the approving officer must record satisfaction and reasons, rendering the issuance of notice and consequential assessment legally unsustainable. The tribunal relied on precedent holding similar formulaic endorsements inadequate, and accordingly quashed the notice for reopening and the assessment framed following that approval for want of valid administrative satisfaction.
Reopening of assessment was held invalid where the PCIT's approval consisted only of the terse statement "yes, I am satisfied" without recorded reasons; such mechanical approval fails the requirement that the approving officer must record satisfaction and reasons, rendering the issuance of notice and consequential assessment legally unsustainable. The tribunal relied on precedent holding similar formulaic endorsements inadequate, and accordingly quashed the notice for reopening and the assessment framed following that approval for want of valid administrative satisfaction.
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