https://www.taxtmi.com/caselaws?id=753415 ITAT Delhi quashed reassessment proceedings u/s 147 after finding that JCIT's approval was granted mechanically without proper application of mind. The JCIT merely recorded "Yes, I am satisfied" without demonstrating actual satisfaction that the case warranted notice u/s 148. Following Pioneer Town Planner Pvt. Ltd. and Chhugamal Rajpal precedents, the Tribunal held that such ritualistic approval defeats the safeguard purpose of requiring higher official approval. The mechanical recording of permission without meaningful consideration rendered the reassessment notice invalid. Decision favored the assessee. en-us Wed, 29 May 2024 00:00:00 +0530 Fri, 31 May 2024 16:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753415 ITAT Delhi quashed reassessment proceedings u/s 147 after finding that JCIT's approval was granted mechanically without proper application of mind. The JCIT merely recorded "Yes, I am satisfied" without demonstrating actual satisfaction that the case warranted notice u/s 148. Following Pioneer Town Planner Pvt. Ltd. and Chhugamal Rajpal precedents, the Tribunal held that such ritualistic approval defeats the safeguard purpose of requiring higher official approval. The mechanical recording of permission without meaningful consideration rendered the reassessment notice invalid. Decision favored the assessee. Case-Laws Income Tax Wed, 29 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753415