https://www.taxtmi.com/caselaws?id=459826 ITAT Delhi held that reopening of assessment was invalid due to mechanical approval by Commissioner. The AO failed to apply mind while seeking approval under section 151, incorrectly citing non-existent section 147(b) provisions in the proforma. The Commissioner also granted approval mechanically without proper consideration. Following precedent from assessee's own case for AY 2010-11, the Tribunal concluded there was complete non-application of mind by both authorities. Consequently, the reassessment order under sections 143(3) read with 147 was quashed and the assessee's appeal was allowed. en-us Tue, 31 Jan 2023 00:00:00 +0530 Mon, 30 Dec 2024 19:58:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459826 ITAT Delhi held that reopening of assessment was invalid due to mechanical approval by Commissioner. The AO failed to apply mind while seeking approval under section 151, incorrectly citing non-existent section 147(b) provisions in the proforma. The Commissioner also granted approval mechanically without proper consideration. Following precedent from assessee's own case for AY 2010-11, the Tribunal concluded there was complete non-application of mind by both authorities. Consequently, the reassessment order under sections 143(3) read with 147 was quashed and the assessee's appeal was allowed. Case-Laws Income Tax Tue, 31 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459826