Reassessment Quashed as Mechanical Approval u/s 151 & Jurisdiction Wrongly Assumed by ITO

Vipul Agrawal Vs ACIT (ITAT Delhi) Mechanical approval U/s 151 invalid – Jurisdiction wrongly assumed by ITO despite CBDT Instruction No. 1/2011 – Reassessment quashed: ITAT Delhi The ITAT Delhi Bench heard the appeal of the individual, where reassessment was initiated u/s 147. The Tribunal examined the validity of approval u/s 151 and found that the PCIT had granted sanction mechanically, merely stating “satisfied/approved” without recording reasons, which courts have consistently held to be invalid. Further, as per CBDT Instruction No. 1/2011 dated 31.01.2011, since the asses...