Mechanical Sanction Voids Reopening Under Section 147: ITAT Delhi

Singhal Fasteners Company Private Limited Vs ITO (ITAT Delhi) Mechanical Sanction Invalidates Reopening – ITAT Delhi Quashes Reassessment The Delhi Bench of the ITAT allowed the assessee’s appeal for AY 2006-07 and quashed the reassessment proceedings on the ground of mechanical approval for reopening. The Tribunal admitted an additional legal ground, holding that it went to the root of jurisdiction and could be raised at any stage. On facts, the Assessing Officer had reopened the assessment solely on information from the Investigation Wing alleging accommodation entries, without independe...