https://www.taxtmi.com/caselaws?id=779899 ITAT Delhi-AT held the reassessment notice invalid ab initio. The AO recorded two different reasons for reopening and obtained two separate s.151 approvals; the online approval was digitally unsigned and contained factual discrepancies, while a subsequent manual approval superseded it. Because the later manual approval was communicated only after issuance of the s.148 notice, the Tribunal found the notice invalid and void. The Tribunal rejected the contention of borrowed satisfaction and emphasized lack of valid, independently effective sanction under s.151. en-us Tue, 23 Sep 2025 00:00:00 +0530 Mon, 13 Oct 2025 17:04:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779899 ITAT Delhi-AT held the reassessment notice invalid ab initio. The AO recorded two different reasons for reopening and obtained two separate s.151 approvals; the online approval was digitally unsigned and contained factual discrepancies, while a subsequent manual approval superseded it. Because the later manual approval was communicated only after issuance of the s.148 notice, the Tribunal found the notice invalid and void. The Tribunal rejected the contention of borrowed satisfaction and emphasized lack of valid, independently effective sanction under s.151. Case-Laws Income Tax Tue, 23 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779899