Approval for reopening by observing merely ‘जी हाँ मैं संतुष्ट हूँ’ is not legally tenable

Shri Ghanshyam Vs ITO (ITAT Agra) In present case, the ld. Additional CIT granted the approval by observing merely that he was satisfied. Sections 147 and 148 of the IT Act, it is trite, are charter to the Revenue to reopen completed assessments. Section 151 of the Act provides a safe-guard that the sword of section 147 of the Act may not be used unless the competent statutory officer is satisfied that the AO has good and adequate reasons to invoke the reopening provisions. As per the mandate of section 151 (2) of the Act, the Competent Authority has to examine the reasons, material or grounds...