The petitioner challenged the reassessment re assessment notice and order disposing the objection on various grounds. One of the ground was approval for reassessment notice was granted in mechanically done a ministerial job.  Allowing the petition the Court held that it is settled law as held by the Division Bench of this court in German Remedies Ltd. v. DCIT (2006) 287 ITR 494 (Bom )(HC) that while granting approval it was obligatory on the part of the PCIT to verify whether there was any failure on the part of the assessee to disclose full and true relevant facts in the return of income filed for the assessment of income of that assessment order. If the PCIT had only read the reasons and also the form for recording the reasons together and referred to other documents in the file, none of which seems to have been done, he would have sent the file back to the person who has filled the form for recording the reasons. Petitioner is justified in raising a contention that the approval granted itself suffered from non-application of mind.  Notice of reassessment and order disposing objection was quashed. (WP No. 3101 of 2019, dt. 22-12-21)

Kandoi Polytex Pvt Ltd. v. ACIT   (Bom.)(HC)(UR)