ITO v. Virat Credit & Holdings Pvt. Ltd. (Delhi)(Trib) , www.itatonline.org

S. 151 : Reassessment – Sanction for issue of notice –Mechanical approval was held to be bad in law [ S. 147, 148 ]

Allowing the cross objection of the assessee the Tribunal held that ; The grant of approval by the CIT with the words “Yes. I am satisfied” proves that the sanction is merely mechanical and he has not applied independent mind while according sanction as there is not an iota of material on record as to what documents he had perused and what were the reasons for his being satisfied to accord the sanction to initiate the reopening of assessment u/s 148 of the Act. (AY. 2005-06)