United Electrical Co. (P.) Ltd. v. CIT

258 ITR 317High Court2002#249 most cited

What is United Electrical Co. (P.) Ltd. v. CIT authority for?

Reassessment proceedings under Section 147 cannot be initiated based on general or vague information lacking a specific link to the assessee's transaction, and requires the Assessing Officer to apply an independent mind and form a 'reason to believe' based on reasonable grounds, not mere suspicion.

309

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2007 to 2026.

Also referred to as

United Electrical Co. v. CIT · Section 147 · Section 148 · reason to believe · reassessment validity · vague information · bogus transactions · independent application of mind · escaped assessment

Also reported as

125 Taxmann 775

Sections most often in play

Section 148Section 143(3)Section 147Section 151Section 153ASection 153DSection 132Section 144

Issues it is cited on

section 10(31a)section 100section 76section 142(2c)section 153b(1)(b)section 144basection 153b(1)rectification under section 154section 158bcsection 2(22)section 206csection 2(22)(e)

Judgments citing United Electrical Co. (P.) Ltd. v. CIT

Smt Pooja Sekhari, New Delhi vs. ACIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 1766/DEL/2017[2010-11]Status: DisposedITAT Delhi30 Sept 2021AY 2010-11

Bench: Shri G.S.Pannu & Shri Kul Bharat

…o cross - examine has been provided by the lower authorities, even though the same was specifically requested before the learned CIT(A). In this regard, reliance is placed on following case laws: a) [2015] 127 DTR 241 (SC) Andaman Timber Industries VS. CCE b) 258 ITR 317 (Del) United Electricals vs. CIT c) [1980] 125 ITR 713 (SC) KishinchandChellaram vs. CIT d) IT (SS) A. No. 12/D/07 Shri RadheyShyam Bansal vs ACIT e) IT( SS) No. 233 and 234/D/2006 dated 19.09.2008 Shri Manit Gulati and Sandeep Gulati f) 109 TTJ 700 (Del) SMC Share Brokers Ltd. vs DCIT affirmed in 288 ITR 345 (Del) CIT vs. SMC Share Broker Ltd. g…

Shri Gaurav Sekhari, New Delhi vs. ACIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 1765/DEL/2017[2010-11]Status: DisposedITAT Delhi30 Sept 2021AY 2010-11

Bench: Shri G.S.Pannu & Shri Kul Bharat

…o cross - examine has been provided by the lower authorities, even though the same was specifically requested before the learned CIT(A). In this regard, reliance is placed on following case laws: a) [2015] 127 DTR 241 (SC) Andaman Timber Industries VS. CCE b) 258 ITR 317 (Del) United Electricals vs. CIT c) [1980] 125 ITR 713 (SC) KishinchandChellaram vs. CIT d) IT (SS) A. No. 12/D/07 Shri RadheyShyam Bansal vs ACIT e) IT( SS) No. 233 and 234/D/2006 dated 19.09.2008 Shri Manit Gulati and Sandeep Gulati f) 109 TTJ 700 (Del) SMC Share Brokers Ltd. vs DCIT affirmed in 288 ITR 345 (Del) CIT vs. SMC Share Broker Ltd. g…

Shri Bhupinder Kumar Sekhri, New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 5378/DEL/2014[2010-11]Status: DisposedITAT Delhi30 Sept 2021AY 2010-11

Bench: Shri G.S.Pannu & Shri Kul Bharat

…o cross - examine has been provided by the lower authorities, even though the same was specifically requested before the learned CIT(A). In this regard, reliance is placed on following case laws: a) [2015] 127 DTR 241 (SC) Andaman Timber Industries VS. CCE b) 258 ITR 317 (Del) United Electricals vs. CIT c) [1980] 125 ITR 713 (SC) KishinchandChellaram vs. CIT d) IT (SS) A. No. 12/D/07 Shri RadheyShyam Bansal vs ACIT e) IT( SS) No. 233 and 234/D/2006 dated 19.09.2008 Shri Manit Gulati and Sandeep Gulati f) 109 TTJ 700 (Del) SMC Share Brokers Ltd. vs DCIT affirmed in 288 ITR 345 (Del) CIT vs. SMC Share Broker Ltd. g…

Shri Bhupinder Kumar Sekhri, New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 5377/DEL/2014[2009-10]Status: DisposedITAT Delhi30 Sept 2021AY 2009-10

Bench: Shri G.S.Pannu & Shri Kul Bharat

…o cross - examine has been provided by the lower authorities, even though the same was specifically requested before the learned CIT(A). In this regard, reliance is placed on following case laws: a) [2015] 127 DTR 241 (SC) Andaman Timber Industries VS. CCE b) 258 ITR 317 (Del) United Electricals vs. CIT c) [1980] 125 ITR 713 (SC) KishinchandChellaram vs. CIT d) IT (SS) A. No. 12/D/07 Shri RadheyShyam Bansal vs ACIT e) IT( SS) No. 233 and 234/D/2006 dated 19.09.2008 Shri Manit Gulati and Sandeep Gulati f) 109 TTJ 700 (Del) SMC Share Brokers Ltd. vs DCIT affirmed in 288 ITR 345 (Del) CIT vs. SMC Share Broker Ltd. g…

M/S. Keerthi International Products Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 5375/DEL/2014[2008-09]Status: DisposedITAT Delhi30 Sept 2021AY 2008-09

Bench: Shri G.S.Pannu & Shri Kul Bharat

…o cross - examine has been provided by the lower authorities, even though the same was specifically requested before the learned CIT(A). In this regard, reliance is placed on following case laws: a) [2015] 127 DTR 241 (SC) Andaman Timber Industries VS. CCE b) 258 ITR 317 (Del) United Electricals vs. CIT c) [1980] 125 ITR 713 (SC) KishinchandChellaram vs. CIT d) IT (SS) A. No. 12/D/07 Shri RadheyShyam Bansal vs ACIT e) IT( SS) No. 233 and 234/D/2006 dated 19.09.2008 Shri Manit Gulati and Sandeep Gulati f) 109 TTJ 700 (Del) SMC Share Brokers Ltd. vs DCIT affirmed in 288 ITR 345 (Del) CIT vs. SMC Share Broker Ltd. g…

M/S. Nova Infratech Pvt. Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 5364/DEL/2014[2010-11]Status: DisposedITAT Delhi30 Sept 2021AY 2010-11

Bench: Shri G.S.Pannu & Shri Kul Bharat

…o cross - examine has been provided by the lower authorities, even though the same was specifically requested before the learned CIT(A). In this regard, reliance is placed on following case laws: a) [2015] 127 DTR 241 (SC) Andaman Timber Industries VS. CCE b) 258 ITR 317 (Del) United Electricals vs. CIT c) [1980] 125 ITR 713 (SC) KishinchandChellaram vs. CIT d) IT (SS) A. No. 12/D/07 Shri RadheyShyam Bansal vs ACIT e) IT( SS) No. 233 and 234/D/2006 dated 19.09.2008 Shri Manit Gulati and Sandeep Gulati f) 109 TTJ 700 (Del) SMC Share Brokers Ltd. vs DCIT affirmed in 288 ITR 345 (Del) CIT vs. SMC Share Broker Ltd. g…

Smt. Shobha Sekhri, New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 5362/DEL/2014[2009-10]Status: DisposedITAT Delhi30 Sept 2021AY 2009-10

Bench: Shri G.S.Pannu & Shri Kul Bharat

…o cross - examine has been provided by the lower authorities, even though the same was specifically requested before the learned CIT(A). In this regard, reliance is placed on following case laws: a) [2015] 127 DTR 241 (SC) Andaman Timber Industries VS. CCE b) 258 ITR 317 (Del) United Electricals vs. CIT c) [1980] 125 ITR 713 (SC) KishinchandChellaram vs. CIT d) IT (SS) A. No. 12/D/07 Shri RadheyShyam Bansal vs ACIT e) IT( SS) No. 233 and 234/D/2006 dated 19.09.2008 Shri Manit Gulati and Sandeep Gulati f) 109 TTJ 700 (Del) SMC Share Brokers Ltd. vs DCIT affirmed in 288 ITR 345 (Del) CIT vs. SMC Share Broker Ltd. g…

Smt. Puja Sekhri, New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 5361/DEL/2014[2010-11]Status: DisposedITAT Delhi30 Sept 2021AY 2010-11

Bench: Shri G.S.Pannu & Shri Kul Bharat

…o cross - examine has been provided by the lower authorities, even though the same was specifically requested before the learned CIT(A). In this regard, reliance is placed on following case laws: a) [2015] 127 DTR 241 (SC) Andaman Timber Industries VS. CCE b) 258 ITR 317 (Del) United Electricals vs. CIT c) [1980] 125 ITR 713 (SC) KishinchandChellaram vs. CIT d) IT (SS) A. No. 12/D/07 Shri RadheyShyam Bansal vs ACIT e) IT( SS) No. 233 and 234/D/2006 dated 19.09.2008 Shri Manit Gulati and Sandeep Gulati f) 109 TTJ 700 (Del) SMC Share Brokers Ltd. vs DCIT affirmed in 288 ITR 345 (Del) CIT vs. SMC Share Broker Ltd. g…

Smt. Puja Sekhri, New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 5360/DEL/2014[2009-10]Status: DisposedITAT Delhi30 Sept 2021AY 2009-10

Bench: Shri G.S.Pannu & Shri Kul Bharat

…o cross - examine has been provided by the lower authorities, even though the same was specifically requested before the learned CIT(A). In this regard, reliance is placed on following case laws: a) [2015] 127 DTR 241 (SC) Andaman Timber Industries VS. CCE b) 258 ITR 317 (Del) United Electricals vs. CIT c) [1980] 125 ITR 713 (SC) KishinchandChellaram vs. CIT d) IT (SS) A. No. 12/D/07 Shri RadheyShyam Bansal vs ACIT e) IT( SS) No. 233 and 234/D/2006 dated 19.09.2008 Shri Manit Gulati and Sandeep Gulati f) 109 TTJ 700 (Del) SMC Share Brokers Ltd. vs DCIT affirmed in 288 ITR 345 (Del) CIT vs. SMC Share Broker Ltd. g…

Sh. Kapil Sekhri, New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 5315/DEL/2014[2010-11]Status: DisposedITAT Delhi30 Sept 2021AY 2010-11

Bench: Shri G.S.Pannu & Shri Kul Bharat

…o cross - examine has been provided by the lower authorities, even though the same was specifically requested before the learned CIT(A). In this regard, reliance is placed on following case laws: a) [2015] 127 DTR 241 (SC) Andaman Timber Industries VS. CCE b) 258 ITR 317 (Del) United Electricals vs. CIT c) [1980] 125 ITR 713 (SC) KishinchandChellaram vs. CIT d) IT (SS) A. No. 12/D/07 Shri RadheyShyam Bansal vs ACIT e) IT( SS) No. 233 and 234/D/2006 dated 19.09.2008 Shri Manit Gulati and Sandeep Gulati f) 109 TTJ 700 (Del) SMC Share Brokers Ltd. vs DCIT affirmed in 288 ITR 345 (Del) CIT vs. SMC Share Broker Ltd. g…

Sh. Kapil Sekhri, New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 5314/DEL/2014[2009-10]Status: DisposedITAT Delhi30 Sept 2021AY 2009-10

Bench: Shri G.S.Pannu & Shri Kul Bharat

…o cross - examine has been provided by the lower authorities, even though the same was specifically requested before the learned CIT(A). In this regard, reliance is placed on following case laws: a) [2015] 127 DTR 241 (SC) Andaman Timber Industries VS. CCE b) 258 ITR 317 (Del) United Electricals vs. CIT c) [1980] 125 ITR 713 (SC) KishinchandChellaram vs. CIT d) IT (SS) A. No. 12/D/07 Shri RadheyShyam Bansal vs ACIT e) IT( SS) No. 233 and 234/D/2006 dated 19.09.2008 Shri Manit Gulati and Sandeep Gulati f) 109 TTJ 700 (Del) SMC Share Brokers Ltd. vs DCIT affirmed in 288 ITR 345 (Del) CIT vs. SMC Share Broker Ltd. g…

Smt. Aarti Sekhri, New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 5313/DEL/2014[2010-11]Status: DisposedITAT Delhi30 Sept 2021AY 2010-11

Bench: Shri G.S.Pannu & Shri Kul Bharat

…o cross - examine has been provided by the lower authorities, even though the same was specifically requested before the learned CIT(A). In this regard, reliance is placed on following case laws: a) [2015] 127 DTR 241 (SC) Andaman Timber Industries VS. CCE b) 258 ITR 317 (Del) United Electricals vs. CIT c) [1980] 125 ITR 713 (SC) KishinchandChellaram vs. CIT d) IT (SS) A. No. 12/D/07 Shri RadheyShyam Bansal vs ACIT e) IT( SS) No. 233 and 234/D/2006 dated 19.09.2008 Shri Manit Gulati and Sandeep Gulati f) 109 TTJ 700 (Del) SMC Share Brokers Ltd. vs DCIT affirmed in 288 ITR 345 (Del) CIT vs. SMC Share Broker Ltd. g…

Smt. Aarti Sekhri, New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 5312/DEL/2014[2009-10]Status: DisposedITAT Delhi30 Sept 2021AY 2009-10

Bench: Shri G.S.Pannu & Shri Kul Bharat

…o cross - examine has been provided by the lower authorities, even though the same was specifically requested before the learned CIT(A). In this regard, reliance is placed on following case laws: a) [2015] 127 DTR 241 (SC) Andaman Timber Industries VS. CCE b) 258 ITR 317 (Del) United Electricals vs. CIT c) [1980] 125 ITR 713 (SC) KishinchandChellaram vs. CIT d) IT (SS) A. No. 12/D/07 Shri RadheyShyam Bansal vs ACIT e) IT( SS) No. 233 and 234/D/2006 dated 19.09.2008 Shri Manit Gulati and Sandeep Gulati f) 109 TTJ 700 (Del) SMC Share Brokers Ltd. vs DCIT affirmed in 288 ITR 345 (Del) CIT vs. SMC Share Broker Ltd. g…

Shri Satnam Singh, Jalandhar vs. Income Tax Officer Ward - 1 (4), Jalandhar

In the result, appeal of the assessee is allowed

ITA 579/ASR/2019[2013-14]Status: DisposedITAT Amritsar29 Jun 2021AY 2013-14
For Appellant: Shri Ashray Sarna, C.AFor Respondent: Shri G.S. Bali, D.R
Section 143(3)Section 147Section 151

…8 dt. 19/12/2019 • Dharmender Kumar Vs. ITO in the ITAT Delhi Bench, ITA No. 2728/Del/2018 dt. 16/10/2019 • Ghanshyam Vs. ITO in the ITAT, Agra Bench, ITA Nos. 129 & 238/Agra/2018 • United Electrical Company (P) Ltd. Vs. CIT & Ors. High Court of Delhi, (2002) 258 ITR 317 (Del) • Ladhuram Laxmi Narayan Vs. ITO, Additonal (1976) 102 ITR 595 (Gauhati) • P. Munirathnam Chetty And P.. Vs. ITO, C-Ward And (1975) 101 ITR 385 (AP) Copies of the aforesaid case laws were furnished which are placed on record. 13. In his rival submissions the Ld. DR strongly supported the impugned order passed by the Ld. CIT(A) and further…

Shri Vijay Kumar Agarwal, Jaipur vs. Income Tax Officer, Ward-4-2, Jaipur

In the result, this appeal of the assessee is allowed

ITA 59/JPR/2019[2011-12]Status: DisposedITAT Jaipur24 May 2021AY 2011-12

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 59/Jp/2019 Fu/Kzkj.K O"Kz@Assessment Year :2011-12 Vijay Kumar Agarwal, Cuke I.T.O., Vs. 7/58, Vidhyadhar Nagar, Ward 4(2), Jaipur. Jaipur. Lfkk;H Ys[Kk La-@Thvkbzvkj La-@Pan/Gir No.: Advpa 6150 F Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Pravin Kr. Saraswat (Ca) Jktlo Dh Vksj Ls@ Revenue By : Smt. Rooni Paul (Addl.Cit) Lquokbz Dh Rkjh[K@ Date Of Hearing : 15/03/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 24/05/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. This Is An Appeal Filed By The Assessee Against The Order Of Ld.Cit(A), Ajmer Dated 27/12/2018 For The A.Y. 2011-12 In The Matter Of Order Passed U/S 143(3) Read With Section 147 Of The Income Tax Act, 1961 (In Short, The Act), Wherein Following Grounds Have Been Taken. “1. The Learned C.I.T. (A) Has Erred For Not Considering The Issue For Validity Of Issue Notice U/S 148 Of I.T. Act, 1961, While There Was No Escapement Of Income On Part Of Assessee. The Initiation Of Proceedings Was Only On Behest Of I.T.O. Ward 3(2), Who Has Intimated To A.O. For Advancement Of Loan Rs.53,95,000/- Given By Assessee To Pooja Agarwal, While Concern A.O. Has Accepted Said Loan In Her Hands After Detailed Examination. Hence Initiation Of 2

For Appellant: Shri Pravin Kr. Saraswat (CA)For Respondent: Smt. Rooni Paul (Addl.CIT)
Section 143(3)Section 147Section 148Section 148(2)Section 151

…uty bound to apply his mind to the proposal put up to him for approval in the light of the material relied upon by the Assessing Officer. That power cannot be exercised casually, in a routine and perfunctory manner (United Electrical Co. P. Ltd. v. CIT (2002) 258 ITR 317) d) Additional Commissioner of Income-tax and the Commissioner of Income-tax having simply written” yes, I am satisfied” on the same while according sanction under section 151, does not in any manner shed any light as to whether there was any application of mind at all by the two senior officers. Therefore, sanction granted by the Commissioner o…

ACIT Cir. 12(1)(2), Mumbai vs. Bharti Axa Life Insurance Company Ltd., Mumbai

In the result, the appeal of the revenue is dismissed and cross objection of the assessee is allowed

ITA 2930/MUM/2019[2007-08]Status: DisposedITAT Mumbai31 Mar 2021AY 2007-08
Section 143(3)Section 147Section 149Section 151

…s placed on the following decisions :- (i) Decision of Hon‘ble Supreme Court in the case of Chhugamal Rajpal vs S.P.Chaliha reported in 79 ITR 603 (SC) ; (ii) Decision of Hon‘ble Delhi High Court in the case of United Electrical Co. Pvt Ltd vs CIT reported in 258 ITR 317 (Del); (iii) Decision of Hon‘ble Madhya Pradesh High Court in the case of CIT vs M/s S Goyanka Lime and Chemicals Ltd reported in 231 Taxman 73 (MP) – Special Leave Petition of the revenue was dismissed by the Hon‘ble Apex Court reported in 237 Taxman 378 (SC) ; (iv) Decision of Hon‘ble Calcutta High Court in the case of S P Agarwalla alias Sukhd…

M/S Vvd Constructions Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-7(1)(2), Bangalore

In the result, ITA No.3384/Bang/2018 is allowed, while ITA Nos

ITA 3388/BANG/2018[2015-16]Status: DisposedITAT Bangalore22 Mar 2021AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H. Guruswamy, ITPFor Respondent: Smt. R. Premi, Jt.CIT(DR)(ITAT), Bengaluru
Section 131Section 133ASection 143(3)Section 148Section 36(1)(iii)

…ssive relief was claimed and no excessive losses were claimed, since the AO has not completed the original assessment upon filing of return of income. He relied on the judgment of Hon’ble Delhi High Court in the case of Unique Electrical P. Ltd. & Ors. v. CIT 258 ITR 317 (Del) wherein it has been held that the competent authority is not entitled to grant approval casually or in a routine manner without application of mind. On this ground also, he prayed for quashing the assessment itself. 37. The ld. DR submitted that as per the records, the only notice u/s. 148 was on 27.03.2017 and not 21.11.2016. Regarding ser…

M/S Vvd Constructions Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-7(1)(2), Bangalore

In the result, ITA No.3384/Bang/2018 is allowed, while ITA Nos

ITA 3387/BANG/2018[2013-14]Status: DisposedITAT Bangalore22 Mar 2021AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H. Guruswamy, ITPFor Respondent: Smt. R. Premi, Jt.CIT(DR)(ITAT), Bengaluru
Section 131Section 133ASection 143(3)Section 148Section 36(1)(iii)

…ssive relief was claimed and no excessive losses were claimed, since the AO has not completed the original assessment upon filing of return of income. He relied on the judgment of Hon’ble Delhi High Court in the case of Unique Electrical P. Ltd. & Ors. v. CIT 258 ITR 317 (Del) wherein it has been held that the competent authority is not entitled to grant approval casually or in a routine manner without application of mind. On this ground also, he prayed for quashing the assessment itself. 37. The ld. DR submitted that as per the records, the only notice u/s. 148 was on 27.03.2017 and not 21.11.2016. Regarding ser…

M/S Vvd Constructions Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-7(1)(2), Bangalore

In the result, ITA No.3384/Bang/2018 is allowed, while ITA Nos

ITA 3386/BANG/2018[2012-13]Status: DisposedITAT Bangalore22 Mar 2021AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H. Guruswamy, ITPFor Respondent: Smt. R. Premi, Jt.CIT(DR)(ITAT), Bengaluru
Section 131Section 133ASection 143(3)Section 148Section 36(1)(iii)

…ssive relief was claimed and no excessive losses were claimed, since the AO has not completed the original assessment upon filing of return of income. He relied on the judgment of Hon’ble Delhi High Court in the case of Unique Electrical P. Ltd. & Ors. v. CIT 258 ITR 317 (Del) wherein it has been held that the competent authority is not entitled to grant approval casually or in a routine manner without application of mind. On this ground also, he prayed for quashing the assessment itself. 37. The ld. DR submitted that as per the records, the only notice u/s. 148 was on 27.03.2017 and not 21.11.2016. Regarding ser…

M/S Vvd Constructions Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-7(1)(2), Bangalore

In the result, ITA No.3384/Bang/2018 is allowed, while ITA Nos

ITA 3385/BANG/2018[2011-12]Status: DisposedITAT Bangalore22 Mar 2021AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H. Guruswamy, ITPFor Respondent: Smt. R. Premi, Jt.CIT(DR)(ITAT), Bengaluru
Section 131Section 133ASection 143(3)Section 148Section 36(1)(iii)

…ssive relief was claimed and no excessive losses were claimed, since the AO has not completed the original assessment upon filing of return of income. He relied on the judgment of Hon’ble Delhi High Court in the case of Unique Electrical P. Ltd. & Ors. v. CIT 258 ITR 317 (Del) wherein it has been held that the competent authority is not entitled to grant approval casually or in a routine manner without application of mind. On this ground also, he prayed for quashing the assessment itself. 37. The ld. DR submitted that as per the records, the only notice u/s. 148 was on 27.03.2017 and not 21.11.2016. Regarding ser…