https://www.taxtmi.com/caselaws?id=757181 Delhi HC held that reopening of assessment under Section 147 was invalid due to lack of proper sanction under Section 151. The PCIT granted approval for 111 reassessment cases through a general order without applying independent mind or recording satisfaction based on material facts of individual cases. The court emphasized that approval is a meaningful safeguard, not a mechanical formality, requiring the competent authority to examine case-specific material before granting sanction. Since the blanket approval failed to meet Section 151 requirements, the Section 148 notice and subsequent proceedings were quashed, deciding in favor of the assessee. en-us Wed, 14 Aug 2024 00:00:00 +0530 Wed, 09 Jul 2025 15:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757181 Delhi HC held that reopening of assessment under Section 147 was invalid due to lack of proper sanction under Section 151. The PCIT granted approval for 111 reassessment cases through a general order without applying independent mind or recording satisfaction based on material facts of individual cases. The court emphasized that approval is a meaningful safeguard, not a mechanical formality, requiring the competent authority to examine case-specific material before granting sanction. Since the blanket approval failed to meet Section 151 requirements, the Section 148 notice and subsequent proceedings were quashed, deciding in favor of the assessee. Case-Laws Income Tax Wed, 14 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757181