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In the background of the aforesaid discussions and respectfully following the precedents, as aforesaid, I am of the considered view that approval granted by the Pr. CIT-4, New Delhi is a mechanical and without application of mind, which is not valid for initiating the reassessment proceedings issue of notice u/s. 148 of the I.T. Act, 1961 and is not in accordance with section 151 of the I.T. Act, 1961, thus, the notice issued u/s. 148 of the Act is invalid and accordingly the reopening in this is bad in law and therefore, the same is hereby quashed.

Shanti Prime Publication Pvt. Ltd.

Section 147 of Income tax Act, 1961— Re-opening of assessment—This appeal filed by the assessee is directed against the order passed by the CIT(A) in relation to reassessment.

Held that—I am of the considered view that approval granted by the Pr. CIT-4, New Delhi is a mechanical and without application of mind, which is not valid for initiating the reassessment proceedings issue of notice u/s. 148 of the I.T. Act, 1961 and is not in accordance with section 151 of the I.T. Act, 1961, thus, the notice issued u/s. 148 of the Act is invalid and accordingly the reopening in this is bad in law and therefore, the same is hereby quashed.[HEAT FLOWN ELECTRICALS PVT. LTD. VERSUS ITO, WARD 11 (2) , NEW DELHI][2019] 20 ITCD Online (18) [ITAT DELHI]

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