https://www.taxtmi.com/caselaws?id=775026 ITAT Delhi quashed reassessment proceedings initiated under section 147 due to invalid sanction under section 151. The Pr.CIT provided mechanical approval by merely signing a standard proforma without recording any specific reasons or date, stating only "it is fit case for issue of notice u/s 148 for reopening." The tribunal found this constituted mechanical approval violating section 151 requirements. Additionally, the AO failed to supply reasons for reopening to the assessee during assessment proceedings, though mentioned in the assessment order. The tribunal held that such procedural deficiencies rendered the reassessment proceedings invalid and ordered their quashing, emphasizing that proper application of mind and communication of reasons to the assessee are mandatory requirements for valid reassessment under the Income Tax Act. en-us Wed, 18 Jun 2025 00:00:00 +0530 Fri, 18 Jul 2025 08:22:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775026 ITAT Delhi quashed reassessment proceedings initiated under section 147 due to invalid sanction under section 151. The Pr.CIT provided mechanical approval by merely signing a standard proforma without recording any specific reasons or date, stating only "it is fit case for issue of notice u/s 148 for reopening." The tribunal found this constituted mechanical approval violating section 151 requirements. Additionally, the AO failed to supply reasons for reopening to the assessee during assessment proceedings, though mentioned in the assessment order. The tribunal held that such procedural deficiencies rendered the reassessment proceedings invalid and ordered their quashing, emphasizing that proper application of mind and communication of reasons to the assessee are mandatory requirements for valid reassessment under the Income Tax Act. Case-Laws Income Tax Wed, 18 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775026