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Tax Reassessment Quashed: Section 147 Reopening Flawed by Mechanical Approval Process u/s 151(1) Lacking Independent Judgment.
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....Reopening of assessment u/s 147 - approval u/s 151(1) - Pr. CIT, has accorded approval for issuing notice u/s 148 in a very routine, mechanical manner & without application of mind by simply putting her signatures below the rubber stamped ‘Yes, satisfied - not sufficient - reassessment quashed....