Scrutiny of Income Tax Assessment Reopening: Section 147 and Validity of Approvals u/s 151 Questioned for Lacking Due Diligence.

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....Reopening of assessment u/s 147 - Validity of approval granted u/s 151 - without examining the facts on record, both the Additional CIT and CIT have granted approval under Section 151. Granting approval under Section 151 of the Act is not an empty formality. Approval has to be granted with caution and proper application of mind to the facts and material on record to prevent miscarriage of justice - AT....