Statutory refund interest requires correction of short computation and compensation where admitted interest remains unpaid through administrative dela...
Sanction for reopening was held invalid where the competent authority merely affixed rubber-stamp endorsements such as "Yes I am satisfied" without showing independent application of mind. The Tribunal treated the approval requirement under section 151 as a substantive safeguard, and applied the principles in S. Goyanka Lime & Chemical and Pioneer Town Planners to hold that mechanical sanction cannot validate reassessment. As the notices under section 148 were issued on the basis of such defective approval, they were bad in law and the consequential reassessment orders for the relevant assessment years were quashed.
Sanction for reopening was held invalid where the competent authority merely affixed rubber-stamp endorsements such as "Yes I am satisfied" without showing independent application of mind. The Tribunal treated the approval requirement under section 151 as a substantive safeguard, and applied the principles in S. Goyanka Lime & Chemical and Pioneer Town Planners to hold that mechanical sanction cannot validate reassessment. As the notices under section 148 were issued on the basis of such defective approval, they were bad in law and the consequential reassessment orders for the relevant assessment years were quashed.
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