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Reopening of assessment failed because the sanction under section 151 was mechanical and not granted with application of mind by the competent authority. The approving authority merely recorded that it was a fit case for issuing notice under section 148, without proper particulars such as the date of approval or any meaningful consideration of the proposal. Following settled law that such perfunctory approval is invalid, the ITAT held that the statutory precondition for reopening was not met. Accordingly, the entire reassessment proceedings were quashed.
Reopening of assessment failed because the sanction under section 151 was mechanical and not granted with application of mind by the competent authority. The approving authority merely recorded that it was a fit case for issuing notice under section 148, without proper particulars such as the date of approval or any meaningful consideration of the proposal. Following settled law that such perfunctory approval is invalid, the ITAT held that the statutory precondition for reopening was not met. Accordingly, the entire reassessment proceedings were quashed.
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