Undated Reasons & Absence of Section 151 Sanction: Delhi ITAT Quashes Reopening

Arpit Goel Vs ITO (ITAT Delhi) Appeals  filed by the Assessee against different orders of CIT(A)in sustaining the addition made u/s 69A. Assessee  submitted that the AO reopened the assessment by issue of notice u/s 148   without the approval from the appropriate authority u/s 151 & therefore submits that   the consequential reassessments made by issue of notice u/s 148 in the absence of any approval of such reassessments are bad in law & void ab initio. Tribunal noted that the reasons recorded for initiation of proceedings u/s 147/148 issued by the AO for the AYs 2009-10 t...