Reassessment Quashed – Section 151 Approval Held Mechanical; No Application of Mind by PCIT

Tribhawan Vs ITO (ITAT Delhi) The Assessee filed the appeal with a delay of 473 days explaining that Ld.CIT(A) had granted time to submit written submissions up to 14.08.2023 but passed the appellate order prematurely on 10.08.2023. A rectification petition u/s 154 was pursued, causing delay. Tribunal accepted that sufficient cause existed & condoned the delay. Assessee raised an additional legal ground contending that the approval u/s 151 for reopening was mechanical & without application of mind. Tribunal noted that reasons recorded for reopening were based solely on cash deposits of...