https://www.taxtmi.com/caselaws?id=764441 The ITAT Delhi quashed a reassessment order under section 147 due to invalid approval granted under section 151. The Additional CIT's sanction was based on incorrect facts, believing the assessee had not filed returns and engaged in substantial land deals. The approval was found to be a "rubber stamp" without proper application of mind or addressing specific reasons for reopening. Following Delhi HC precedents in N.C. Cables, Pioneer Town Planners, and Manujendra Shah cases, the tribunal held that omnibus approvals without substantive consideration violate section 151's requirements. Since the reassessment's validity depends on valid section 151 approval, the entire proceedings were deemed without legal sanction. The assessee's appeal was allowed. en-us Wed, 08 Jan 2025 00:00:00 +0530 Fri, 10 Jan 2025 08:57:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764441 The ITAT Delhi quashed a reassessment order under section 147 due to invalid approval granted under section 151. The Additional CIT's sanction was based on incorrect facts, believing the assessee had not filed returns and engaged in substantial land deals. The approval was found to be a "rubber stamp" without proper application of mind or addressing specific reasons for reopening. Following Delhi HC precedents in N.C. Cables, Pioneer Town Planners, and Manujendra Shah cases, the tribunal held that omnibus approvals without substantive consideration violate section 151's requirements. Since the reassessment's validity depends on valid section 151 approval, the entire proceedings were deemed without legal sanction. The assessee's appeal was allowed. Case-Laws Income Tax Wed, 08 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764441