Mere “Approved” Not Enough: ITAT Voids Reopening for Mechanical Sanction

Sun Itech And Broadcast Private Limited Vs ITO (ITAT Delhi) Reassessment Quashed for Mechanical Sanction u/s 151 – Mere “Approved” Not a Valid Application of Mind The Delhi ITAT allowed the assessee’s appeal and quashed the entire reassessment for AY 2011-12 on the ground that the mandatory approval under Section 151 for reopening was granted in a purely mechanical manner. The Tribunal found that the PCIT had granted sanction by merely writing “Approved / Yes, I am satisfied” without recording any reasons or demonstrating independent application of mind. Relying on binding preceden...