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Reassessment Quashed as Mechanical Approval u/s 151 & Jurisdiction Wrongly Assumed by ITO
Case Law Details
- Case Name
- Vipul Agrawal Vs ACIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2012-13
- Courts
- All ITAT, ITAT Delhi
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Vipul Agrawal Vs ACIT (ITAT Delhi)
Mechanical approval U/s 151 invalid – Jurisdiction wrongly assumed by ITO despite CBDT Instruction No. 1/2011 – Reassessment quashed: ITAT Delhi
The ITAT Delhi Bench heard the appeal of the individual, where reassessment was initiated u/s 147. The Tribunal examined the validity of approval u/s 151 and found that the PCIT had granted sanction mechanically, merely stating “satisfied/approved” without recording reasons, which courts have consistently held to be invalid.
Further, as per CBDT Instruction No. 1/2011 dated 31.01.2011...





