https://www.taxtmi.com/caselaws?id=754050 ITAT Delhi held that reassessment proceedings u/s 147 were invalid due to defective approval by Pr.CIT u/s 151. The sanctioning authority failed to apply mind while granting approval, merely recording "action u/s 148 approved" without examining crucial aspects like cash transactions being recorded in books and plausibility of non-disclosure allegations. The approval was mechanical and rubber-stamped, lacking proper application of mind required under s. 151 as a safeguard against arbitrary exercise of powers. Since valid approval u/s 151 is prerequisite for reassessment, the defective sanction vitiated subsequent notice u/s 148 and reassessment order. Assessee's appeal was allowed. en-us Thu, 13 Jun 2024 00:00:00 +0530 Fri, 14 Jun 2024 16:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754050 ITAT Delhi held that reassessment proceedings u/s 147 were invalid due to defective approval by Pr.CIT u/s 151. The sanctioning authority failed to apply mind while granting approval, merely recording "action u/s 148 approved" without examining crucial aspects like cash transactions being recorded in books and plausibility of non-disclosure allegations. The approval was mechanical and rubber-stamped, lacking proper application of mind required under s. 151 as a safeguard against arbitrary exercise of powers. Since valid approval u/s 151 is prerequisite for reassessment, the defective sanction vitiated subsequent notice u/s 148 and reassessment order. Assessee's appeal was allowed. Case-Laws Income Tax Thu, 13 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754050