Tribunal condoned the delay in filing of appeal and admitted the additional ground. The Tribunal held that the Principal Commissioner had recorded satisfaction in a mechanical manner without application of mind to accord sanction for issue of notice. Therefore, the reopening of the assessment was liable to be quashed. (AY.2009-10)
TEK Chand v. ITO (2021) 88 ITR 392 (Chd.)(Trib.)
S. 151 : Reassessment-Sanction for issue of notice-Additional ground was admitted-Delay in filing the appeal was condoned-Sanction was mechanical, without application of mind-Order of reassessment was quashed. [S. 147,148, 151, 253, 254(1)]