Reopening Quashed: Mechanical Sec 151 Approval Invalid; “Yes, I am Satisfied” Insufficient: ITAT Kolkata

Kippy Engineering Pvt. Ltd. Vs ACIT (ITAT Kolkata) Reopening Quashed – Mechanical Approval u/s 151 Invalid – “Yes, I am Satisfied” Not Proper Sanction – ITAT Kolkata ITAT Kolkata admitted additional legal ground and quashed reassessment holding that approval granted by PCIT u/s 151 was mechanical and without independent application of mind. Tribunal noted that sanction merely recorded “Yes, I am satisfied, may be reopened” (visible in approval sheet extracted ), which failed to demonstrate objective satisfaction as required under law. Relying on Lakhmani Mewal Das (SC), Jet Airwa...