Reassessment Quashed Because Section 151 Sanction Was Mechanical

Essen Marketing Pvt. Ltd. Vs ITO (ITAT Kolkata) Mechanical “Yes, I Am Satisfied” Approval Sinks Reopening — 148 Notice & Reassessment Quashed Kolkata ITAT quashed the reassessment of Essen Marketing Pvt. Ltd. for AY 2012-13 after holding that the mandatory sanction u/s 151 for reopening was granted in a purely mechanical manner. The reassessment was initiated by issuing notice u/s 148 dated 27-03-2019, based on approval of the PCIT, Kolkata-3, who merely recorded the words “Yes, I am satisfied” without any independent reasoning or application of mind. The Tribunal held that such ...