Approved Isn’t Approval – Mechanical Section U/s 151 Kills Reopening at Birth

Krishan Kumar Bansal Vs Assessing Officer (ITAT Delhi) ITAT Delhi allowed the assessee’s appeal for AY 2017-18 in Krishan Kumar Bansal (Legal Heir), quashing the entire reassessment u/s 147 solely on the ground of mechanical approval u/s 151, without examining merits. The assessee raised additional legal grounds, demonstrating that the JCIT’s sanction dated 20.03.2013 merely recorded “approved” in the remarks column, with no indication of application of mind. The Tribunal accepted these grounds, holding that such ritualistic endorsement does not satisfy the statutory safeguard embedded...