Topic
ITAT Delhi quashes reassessment for AY 2012-13 after finding the prescribed authority’s Section 151 approval lacked independent application of mind. Ruling reaffirms that mechanical approvals violate judicial discipline and render reopening proceedings invalid under CIT vs. S. Goyanka Lime and Chemical Pvt. Ltd. (2015).
ITAT Agra nullified a reassessment under Section 147 after finding the Section 151 approval was a rubber-stamp endorsement without application of mind, reinforcing that procedural compliance is jurisdictional, not formalistic. This ruling impacts all reassessment proceedings where approvals are boilerplate, requiring tax officers to demonstrate genuine scrutiny before reopening assessments.
ITAT Delhi quashed an assessment order where the JCIT's approval under Section 153D was mechanical, lacked application of mind, and omitted mandatory DIN compliance. The ruling reinforces that digital evidence protocols and natural justice principles must govern search assessments to prevent arbitrary tax proceedings.
ITAT Delhi holds that consolidated approval under Section 153D for multiple assessment years is invalid; each year requires independent sanction with application of mind.