Reopening Quashed: Mechanical Sec 151 Approval Invalid; Rubber-Stamp Sanction Cannot Sustain Sec 147 – ITAT Kolkata

Jiya Exim Private Limited Vs ITO (ITAT Kolkata) Reopening Quashed – Mechanical Approval u/s 151 Held Invalid – Rubber Stamp Sanction Cannot Sustain Sec 147 Proceedings – ITAT Kolkata ITAT Kolkata quashed reassessment holding that approval granted by PCIT u/s 151 was mechanical and without recording any independent satisfaction. Tribunal noted from approval forms (pages 3–5) that approving authority merely affixed signature without indicating reasons or application of mind, defeating statutory safeguard intended under Sec 151. Relying on Capital Broadways, S. Goyanka Lime & Chemical...