APC Air Systems P. Ltd. v. ITO (2020)77 ITR 21 (SN) (Delhi)(Trib.)

S. 151 : Reassessment-Sanction for issue of notice-Approval granted in mechanical manner and without application of mind-Reopening is not valid. [S. 147, 148]

Tribunal held  that the approval for initiating reassessment proceedings had been granted by the Additional Commissioner mechanically and without application of mind and was not valid because the remarks did not show which material, information, documents and which other aspects he had been gone through and examined for reaching the satisfaction for granting approval. Thereafter, the AO had mechanically issued notice under S. 148 of the  Act,. The reopening  is held to be bad in law. (AY.2008-09)