S. 151: Sanction granted by writing ‘Yes, I am satisfied’ is not sufficient

Pioneer Town Planners Pvt. Ltd Vs DCIT (ITAT Delhi) We may point out that from the proforma of approval u/s. 151 of the Act placed at pgs. 16-17 of the assessee paper book, it is clear that in column 12 the ACIT has granted approval for the issue of notice u/s. 148 of the Act by writ ng that “Yes, I am satisfied” which is not sufficient to comply with the requirement of s. 151 of the Act. As per ratio of the decision of High Court of Madhya Pradesh in the case of CIT v. M/s. S. Goyanka Lime and Chemical Ltd. (supra), where the JCIT/ACIT has only recorded “Yes I am satsfied” then, it ha...