ITAT Delhi quashes reassessment for quoting repealed section & granting mechanical Approval

Sumit Suneja Vs ACIT (ITAT Delhi) Assessee’s case was reopened u/s 147 based on information of cash deposits (Rs 38,72,062 in PNB & Rs 2,10,600 in South India Bank).  Assessee did not respond during assessment, leading to a best judgment order u/s 144, adding Rs40,82,662 as unexplained deposits. Assessee’s contended that reassessment invalid for non-compliance with mandatory requirements of section 147/148 and that Approval u/s 151 was mechanical & without independent application of mind. AO mentioned non-existent section “147(a)” in approval form (provisions omitted from stat...