https://www.taxtmi.com/caselaws?id=785211 Reopening of assessment under section 147 was challenged on the ground that approval under section 151 was granted mechanically without independent application of mind, relying on shared information from a CBDT OM and third-party search action. Precedents establishing that proforma approvals stating mere concurrence are mechanical were applied to conclude the approval was invalid. Because the competent authority did not exercise the required independent scrutiny when granting approval, the reassessment proceedings based on that approval were quashed and the ground contesting assumption of jurisdiction under section 147 was allowed for the assessee. en-us Wed, 26 Nov 2025 00:00:00 +0530 Tue, 20 Jan 2026 06:31:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785211 Reopening of assessment under section 147 was challenged on the ground that approval under section 151 was granted mechanically without independent application of mind, relying on shared information from a CBDT OM and third-party search action. Precedents establishing that proforma approvals stating mere concurrence are mechanical were applied to conclude the approval was invalid. Because the competent authority did not exercise the required independent scrutiny when granting approval, the reassessment proceedings based on that approval were quashed and the ground contesting assumption of jurisdiction under section 147 was allowed for the assessee. Case-Laws Income Tax Wed, 26 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785211