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Reassessment invalid if satisfaction for reopening recorded in mechanical manner
Case Law Details
- Case Name
- Sungrow Impex Private Limited Vs Income Tax Officer (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2010-2011
- Courts
- All ITAT, ITAT Delhi
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Sungrow Impex Private Limited Vs ITO (ITAT Delhi)
Conclusion: CIT had recorded his satisfaction for reopening of the assessment in a most mechanical manner without considering even the assessment records or the return of income filed by assessee and his satisfaction appeared to be in a ritualistic and formal rather than meaningful. Therefore, such approval under section 151 was totally without application of mind and as such the satisfaction could not be said to be valid in the eyes of Law. Thus, addition on account of unaccounted share application money and commission paid was deleted.
He...
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