Reassessment Notice Invalid If PCIT Approval is Ritualistic & Mechanical: ITAT Delhi

Raghav Technology P. Ltd. Vs ITO (ITAT Delhi) Notice u/s 148 Invalid Without Independent Satisfaction of PCIT, Rules ITAT- Ritualistic & Mechanical Approval Fatal Assessee filed its return for AY 2011-12. Based on Investigation Wing’s report alleging accommodation entries from Surendra Kumar Jain group, the AO reopened assessment u/s 147 after obtaining sanction of the PCIT. The approval recorded by PCIT was merely: “Yes, it is a fit case for issue of notice u/s 148/147”. AO thereafter passed reassessment order making additions. CIT(A) confirmed the reassessment. Assessee’s Argumen...