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TMI Blog2019 (4) TMI 1734X X X X Extracts X X X X X X X X Extracts X X X X ..... ecorded of the given case which can be reflected in the briefest possible manner. Approval was granted by the Pr. CIT-7, New Delhi by noting Yes I am satisfied shows that the approval was given in a mechanical manner without recording proper satisfaction after due application of mind. The Hon ble Delhi High Court in the case of Pr. CIT Vs N. C. Cables Ltd. (supra) has held that mere appending of the expression approved says noting. It is not as if the CIT has to record elaborate reasons for agreeing with the noting put up. At the same time, satisfaction has to be recorded of the given case which can be reflected in the briefest possible manner. In the present case, the exercise appears to have been ritualistic and formal rather than meaning ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of unsecured loans taken from M/s Prayag India (P) Ltd., and more so without appreciating the material on record & without observing principles of natural justice. 4) That in any case and in any view of the matter, action of Ld. CIT(A) in confirming the addition of ₹ 34,00,000/- is bad in law and against the facts and circumstances of case and without considering the material placed on record and by recording incorrect facts and findings. 5) That in any view of the matter and in any case, action of Ld.CIT(A) in confirming the action of Ld. AO that no opportunity to cross examine of the said alleged persons Sh. Deepak Agarwal and Shri Mukesh Agarwal, on the basis of which said addition has been made. 6) That having regard to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ities. 7. I find that the Hon'ble Delhi High Court in the case of Pr. CIT Vs N. C. Cables Ltd. reported in (2017) 98 CCH 10 (Del. HC) has held the mere appending of the expression "approved" says nothing, Commissioner of Income Tax has to record elaborate reasons for agreeing with the noting put up, and at the same time, satisfaction has to be recorded of the given case which can be reflected in the briefest possible manner. 8. I find that the approval was granted by the Pr. CIT-7, New Delhi by noting "Yes I am satisfied" shows that the approval was given in a mechanical manner without recording proper satisfaction after due application of mind. The Hon'ble Delhi High Court in the case of Pr. CIT Vs N. C. Cables Ltd. (supra) has held th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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