Blue Chip Developers P. Ltd. v. ITO (2019) 76 ITR 58 (SN.) (Delhi)(Trib.)

S. 151 : Reassessment-Sanction for issue of notice-Approval of commissioner in a mechanical manner without due application of mind and mentioning only “yes”-Reassessment is not sustainable. [S. 147, 148]

Tribunal held that, PCIT while granting approval for issue of notice u/s. 148 had only mentioned “yes”, which established that the approving authority had given approval to the reopening of the assessment in a mechanical manner without due application of mind. Therefore, reassessment was not sustainable in the eyes of law and had to be quashed. AY. 2009-10)