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    <title>Mechanical sanction for reopening vitiates reassessment where approval reflects non-application of mind and invalid statutory reference.</title>
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    <description>ITAT held that reassessment jurisdiction was vitiated because the approval for reopening reflected clear non-application of mind. The Assessing Officer&#039;s proposal referred to section 147(b), a provision that had ceased to exist, and the sanctioning authority issued only a ritualistic, mechanical approval under section 151 without correcting the obvious errors. On that jurisdictional defect, the reopening was quashed and the assessee&#039;s legal grounds were allowed. The merits of the addition were left open and were not adjudicated.</description>
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    <pubDate>Wed, 03 Jun 2026 08:50:38 +0530</pubDate>
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      <title>Mechanical sanction for reopening vitiates reassessment where approval reflects non-application of mind and invalid statutory reference.</title>
      <link>https://www.taxtmi.com/highlights?id=100396</link>
      <description>ITAT held that reassessment jurisdiction was vitiated because the approval for reopening reflected clear non-application of mind. The Assessing Officer&#039;s proposal referred to section 147(b), a provision that had ceased to exist, and the sanctioning authority issued only a ritualistic, mechanical approval under section 151 without correcting the obvious errors. On that jurisdictional defect, the reopening was quashed and the assessee&#039;s legal grounds were allowed. The merits of the addition were left open and were not adjudicated.</description>
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      <pubDate>Wed, 03 Jun 2026 08:50:38 +0530</pubDate>
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