Section 147 Approval to reopen with mere words “Yes. I am satisfied” not valid

ITO Vs Virat Credit & Holdings Pvt.Ltd (ITAT Delhi)

Apparently, from the approval recorded by CIT and words used that ‘Yes. I am satisfied.’, it has proved on record that the sanction for reopening under section 147  is merely mechanical and Addl.CIT has not applied independent mind while according sanction as there is not an iota of material on record as to what documents he had perused and what were the reasons for his being satisfied to accord the sanction to initiate the reopening of assessme

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