High Court Upholds ITAT Decision: Reopening Assessment u/ss 147/148 Invalid Due to Lack of Proper Sanction u/s 151.

Approval granted to reopen the assessment u/s 147/148 - In the present case, the exercise appears to have been ritualistic and formal rather than meaningful, which is the rationale for the safeguard of an approval by a higher ranking officer - ITAT rightly held that there was no proper application of mind by the concerned sanctioning authority u/s 151 - HC .....

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