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Merely Approval without application of mind not sufficient and renders reopening void
Case Law Details
- Case Name
- ITO Vs M/s. Direct Sales (P) Ltd. (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All ITAT, ITAT Delhi
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Ld. A.R. submitted that the case of the assessee was duly covered in its favour by various orders of Hon’ble Court. It was submitted that necessary satisfaction required u/s 151 was not obtained. Ld. A.R. invited our attention to paper book page 330 and submitted that the Addl. CIT has nowhere recorded his satisfaction by application of his independent mind. He just affixed his signatures and approved it. Ld. A.R. submitted that such a satisfaction is not the satisfaction as required by law. Ld. A.R. further submitted that the reasons recorded were also insufficient and in t...
