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    <title>2026 (1) TMI 613 - ITAT DELHI</title>
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    <description>Reassessment proceedings are invalid where sanction for reopening is granted mechanically without independent application of mind. On the facts described, the reopening was initiated on information from the Investigation Wing, but the Addl. CIT&#039;s approval was found to be mechanical and lacking proper consideration of the material. That defect vitiated the reassessment process, and the reopening was held unsustainable in law. The reassessment was accordingly quashed in favour of the assessee. The stated principle is that sanction for reopening under reassessment provisions must reflect genuine, independent application of mind.</description>
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    <pubDate>Fri, 09 Jan 2026 00:00:00 +0530</pubDate>
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      <title>2026 (1) TMI 613 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=784857</link>
      <description>Reassessment proceedings are invalid where sanction for reopening is granted mechanically without independent application of mind. On the facts described, the reopening was initiated on information from the Investigation Wing, but the Addl. CIT&#039;s approval was found to be mechanical and lacking proper consideration of the material. That defect vitiated the reassessment process, and the reopening was held unsustainable in law. The reassessment was accordingly quashed in favour of the assessee. The stated principle is that sanction for reopening under reassessment provisions must reflect genuine, independent application of mind.</description>
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      <pubDate>Fri, 09 Jan 2026 00:00:00 +0530</pubDate>
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