https://www.taxtmi.com/caselaws?id=759712 Delhi HC held that reopening assessment under section 147 was invalid due to defective sanction under section 151. The PCIT's approval order lacked reasoning and merely stated "Yes I am satisfied" without indicating examination of material or thought process. The court found this ritualistic approach insufficient, emphasizing that valid approval requires discernible satisfaction with reasons linking material to conclusion. The approval being a mere rubber stamp without independent application of mind rendered the section 148 notice invalid. Assessee's appeal was allowed. en-us Thu, 03 Oct 2024 00:00:00 +0530 Sat, 05 Oct 2024 09:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759712 Delhi HC held that reopening assessment under section 147 was invalid due to defective sanction under section 151. The PCIT's approval order lacked reasoning and merely stated "Yes I am satisfied" without indicating examination of material or thought process. The court found this ritualistic approach insufficient, emphasizing that valid approval requires discernible satisfaction with reasons linking material to conclusion. The approval being a mere rubber stamp without independent application of mind rendered the section 148 notice invalid. Assessee's appeal was allowed. Case-Laws Income Tax Thu, 03 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759712