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Reassessment Quashed – Section 151 Approval Held Mechanical; No Application of Mind by PCIT
Case Law Details
- Case Name
- Tribhawan Vs ITO (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2011-12
- Courts
- All ITAT, ITAT Delhi
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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...
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