#tax reassessment validity

ITAT Delhi sets aside reassessment proceedings under Section 147 of the Income Tax Act, 1961, ruling that mere mechanical approval by the prescribed authority without independent application of mind renders the reopening invalid. The judgment reinforces procedural compliance as a safeguard against arbitrary tax reassessments, impacting taxpayers and tax authorities alike.

ITAT Delhi rules that reassessment notices issued under the pre-amendment Section 148 of the Income Tax Act after 01.04.2021 are invalid due to procedural non-compliance. The tribunal relies on the precedent in Sumanjeet Aggarwal v. ITO, emphasizing that the new scheme under Section 148A must be strictly followed. This decision impacts taxpayers facing reassessment proceedings initiated under the old regime post-amendment.