https://www.taxtmi.com/caselaws?id=771666 The ITAT Delhi upheld the validity of reopening assessments under section 148 following prior annulment of assessments completed under section 153C. The tribunal held that the Commissioner applied his mind while granting approval under section 151, being fully aware of case facts from earlier proceedings under section 264. Since the original section 153C assessments were annulled as ab initio void rather than time-barred, the reassessment proceedings were valid. The tribunal distinguished this case from regularization of time-barred proceedings, noting the approval under section 151 was not mechanical and involved proper application of mind by the administrative authority. en-us Mon, 17 Mar 2025 00:00:00 +0530 Tue, 27 May 2025 15:48:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771666 The ITAT Delhi upheld the validity of reopening assessments under section 148 following prior annulment of assessments completed under section 153C. The tribunal held that the Commissioner applied his mind while granting approval under section 151, being fully aware of case facts from earlier proceedings under section 264. Since the original section 153C assessments were annulled as ab initio void rather than time-barred, the reassessment proceedings were valid. The tribunal distinguished this case from regularization of time-barred proceedings, noting the approval under section 151 was not mechanical and involved proper application of mind by the administrative authority. Case-Laws Income Tax Mon, 17 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771666