The assessee before the Tribunal took the ground that that the impugned assessment Order u/s 143(3) r.w.s 147 was passed without complying with the mandatory conditions u/s 147/148 as envisaged by the Act. Additional ground was admitted. 

Tribunal observed that Jt. CIT recorded the satisfaction in a mechanical manner without application of mind, and gave approval by simply stating that “Yes, it is approved for 148 action”. Based on the same it was held that the approval was not valid and consequently the reopening of the assessment on the basis of said approval was also not valid. (AY. 2013-14)