Section 147: Mere ‘Yes’ on approval not amounts to due application of mind

Blue Chip Developers (P) Ltd. Vs. ITO (ITAT Delhi)

Since in the present case the approving authority has given approval to the reopening of assessment in a mechanical manner without due application of mind by only mentioning in Column No. 12 ‘YES’, in the Reasons for Initiating Proceedings u/s. 147 and For obtaining the Approval of the Addl. Commissioner of Income Tax, Delhi-2, New Delhi, a copy of which is placed at page no. 103 of the Paper Book No. 2, and therefore, the legal issue in dispute is squarely covered by the af

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