Case Law Details
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:-
The aforesaid appeal filed by the Revenue and cross objections filed by the assessee are being disposed off by way of consolidated order to avoid repetition of discussion.
2. The Appellant, Income-tax Officer, Ward 17 (4), New Delhi (hereinafter referred to as ‘the Revenue’) by filing the present appeal sought to set aside the impugned order dated 31.10.2011 passed by the Commissioner of Income-tax (Appeals)-XIX, New Delhi qua the assessment year 2005-06 on the grounds inter alia that :-
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