Dy. CIT v. Sandeep Bajaj (2024)113 ITR 8 (SN)(Delhi)(Trib)

S. 151 : Reassessment-Sanction for issue of notice-Joint Commissioner had merely written “Yes, I am satisfied” and not that “It is a fit case for issue of notice under Section 148”-Approval mechanical and not valid. [S. 148, 151(2)]

Held that  the Joint Commissioner had merely written “Yes, I am satisfied”. He had not recorded satisfaction that “it is a fit case for issue of notice under section 148 ” and therefore, the approval under section 151 was only mechanical and not a valid approval. Reassessment notice is quashed.  (AY.2014-15)

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