Reassessment Quashed – Invalid Approval U/s 151 Vitiates Jurisdiction

Makam Industries Pvt Ltd Vs DCIT (ITAT Delhi) The ITAT Delhi allowed the assessee’s appeal and quashed reassessment proceedings on jurisdictional grounds. The assessee’s case had earlier been assessed u/s 153C/143(3), but the AO later reopened the assessment u/s 147 based on investigation information and made addition u/s 68 relating to sale consideration received. The assessee challenged the validity of reopening on the ground that approval u/s 151 granted by the PCIT was mechanical and invalid. The Tribunal observed that the approval column contained only the remark “As per Annexure,�...