Mere Word Satisfied Invalidates Section 148 Approval given without Reasoning

Tek Chand Vs ITO (ITAT Chandigarh) The A.O. obtained the approval of the PR. CIT before issuing the notice under section 148 of the Act. The proposal dt. 11/03/2016 seeking the approval for issuance of notice under section 148 of the Act, by the A.O. is placed at page no. 2 & 3 of the assessee’s paper book. While giving the approval the Ld. PR. CIT, Karnal recorded as under: “ Yes, satisfied, it is a fit case for issue of notice under section 148 “ Sd/- Pr. CIT, Karnal From the aforesaid approval, it is clear that the Ld. Pr. CIT recorded satisfaction in the mechanical manner, withou...