Sanction for reassessment by JC in a mechanical manner is invalid

CIT Vs M/s. S. Goyanka Lime and Chemicals Ltd. (Madhya Pradesh HC)

In this case Joint Commissioner had acted mechanically in order to discharge his statutory obligation properly in the matter of recording sanction as he merely wrote on the format “Yes, I am satisfied” which indicated as if he was to sign only on the dotted line, whereas satisfaction has to be with objectivity on objective material. Thus, reopening of assessment was invalid.

FULL TEXT OF THE HIGH COURT ORDER / JUDGMENT

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