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Section 147 Approval to reopen with mere words “Yes. I am satisfied” not valid
Case Law Details
- Case Name
- ITO Vs Virat Credit & Holdings Pvt.Ltd (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2005-06
- Courts
- All ITAT, ITAT Delhi
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ITO Vs Virat Credit & Holdings Pvt.Ltd (ITAT Delhi)
Apparently, from the approval recorded by CIT and words used that ‘Yes. I am satisfied.’, it has proved on record that the sanction for reopening under section 147 is merely mechanical and Addl.CIT has not applied independent mind while according sanction as there is not an iota of material on record as to what documents he had perused and what were the reasons for his being satisfied to accord the sanction to initiate the reopening of assessment u/s 148 of the Act.
FULL TEXT OF THE ITAT ORDER IS AS FOLLOWS:...
