ITAT Delhi Quashes Income Tax Reassessment for Mechanical Approval

Birpal Vs ITO (ITAT Delhi)

The ITAT Delhi reviewed the appeal filed by Birpal against the income tax reassessment order for the assessment year 2010-11. The issue arose from the reopening of the assessment under Section 147/144 of the Income Tax Act, 1961, where the competent authority, the Principal Commissioner of Income Tax (PCIT), had allegedly given only a mechanical approval for the reassessment, without exercising the mandatory application of mind as required under Section 151 of the Act. The assessee argued that the approval by the PCIT was a mere formal exercise and lacked

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