Pioneer Town Planners Pvt. Ltd. v. DCIT ( 2018) 195 TTJ 388/170 DTR 237/ 66 ITR 47 (SN) ( Delhi)(Trib), www.itatonline.org

S. 151 : Reassessment – Sanction- Sanction granted by writing “Yes, I am satisfied” is not sufficient to comply with the requirement of s. 151 because it means that the approving authority has recorded satisfaction in a mechanical manner and without application of mind-Reassessment is bad in law . [ S.147, 148, 292B ]

Allowing the appeal of the assessee , the Tribunal held that , Sanction granted by writing “Yes, I am satisfied” is not sufficient to comply with the requirement of s. 151 because it means that the approving authority has recorded satisfaction in a mechanical manner and without application of mind. Reassessment is bad in law . ( ITA No.132/Del/2018, dt. 06-08-2018) ( AY. 2009-10)

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