2016 (3) TMI 1377

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.....L. Mourya - DR ORDER PER N.S. SAINI, ACCOUNTANT MEMBER This is an appeal filed by the assessee against the order of Commissioner of Income Tax (Appeals), Ajmer, dated 14/08/2014. 2. In grounds No. 1 to 6, the assessee has challenged the validity of reopening of the assessment under sec. 148 of the Act. 3. Authorized Representative of the assessee argued before us that at page No. 2....

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....to be held as mechanical way of recording satisfaction which accords a sanction clearly unsustainable and hence the order of the Tribunal quashing the reassessment and notice under sec. 148 of the Act was upheld. He further relied on the decision of the Hon'ble Delhi High Court in the case of Central India Electric Supply Co Ltd. v. ITO [(2011) 333 ITR 237 (Del.)] wherein it was held that a me....

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....3;, there was no set out of brief reasons by the JCIT as to why he agreed with the reasons of reopening as stated by the Assessing Officer. Therefore, the approval granted by the JCIT for reopening of the assessment for the Assessment Year 2006-07 was not valid under sec. 151 of the Act. Hence, we quash the issue of notice under sec. 148 of the Act by the Assessing Officer for reopening of the ass....