“sanctioning authority”

ReassessmentSection 151Section 151426 judgments

The decision most relied on for sanctioning authority is CIT v. S. Goyanka Lime & Chemical Ltd. (64 Taxmann.com 313), cited in 340 judgments on BharatTax.

Leading authorities on sanctioning authority

CIT v. S. Goyanka Lime & Chemical Ltd.

64 Taxmann.com 313 · 2015 · Supreme Court

340

citing judgments

A mechanical approval by the prescribed authority under Section 151, made without independent application of mind, vitiates and renders the entire reassessment proceedings invalid. Such approvals, often indicated by brief, unreasoned endorsements, lead to the quashing of the reopening of assessment.

Madhya Pradesh in CIT v. S. Goyanka Lime & Chemicals Ltd.

56 Taxmann.com 390 · 2015 · High Court

188

citing judgments

A sanction for issuing a notice under section 148 is invalid if the sanctioning authority grants approval mechanically, merely recording 'Yes, I am satisfied' without proper application of mind to the reasons for reassessment. The authority must demonstrate proper consideration to fulfill the statutory obligation under section 151.

CIT v. SPL’s Siddhartha Ltd.

345 ITR 223 · 2012 · High Court

164

citing judgments

Reassessment proceedings under Section 147 are invalid if the sanction required under Section 151 is obtained mechanically, without independent application of mind by the sanctioning authority, or is based on borrowed satisfaction.

(P.) Ltd. v. ITO

221 ITR 538 · 1996 · Supreme Court

125

citing judgments

The sanction of a specified authority under Section 151 is a mandatory procedural check before issuing a notice under Section 148. This procedural safeguard aims to prevent mechanical reopening of assessments and harassment of the assessee.

PCIT v. NC Cables Ltd.

391 ITR 11 · 2017 · High Court

104

citing judgments

Approval for reassessment under Section 151 requires the approving authority to apply its mind and form an opinion, not merely endorse it mechanically. Additions under Section 68 cannot be made based on suspicion alone and require conclusive evidence.

Arjun Singh v. ADIT

246 ITR 363 · 2000 · High Court

102

citing judgments

For a valid reassessment, the sanctioning authority must apply its mind to the reasons for reopening the assessment under Section 147. A mechanical endorsement like 'I am satisfied' without considering the material amounts to non-application of mind and invalidates the sanction under Section 151.

Financial Services Pvt. Ltd. v. Dy. CIT

457 ITR 647 · 2023 · High Court

citing judgments

The amended Section 151 of the Income-tax Act, governing the sanction for reassessment proceedings under Sections 148 and 148A, applies to cases initiated under the new reassessment regime. The specified authority for granting such sanction becomes the Principal Chief Commissioner or Principal Director General if more than three years have elapsed from the end of the relevant assessment year.

Ghanshyam K. Khabrani v. ACIT

346 ITR 443 · 2012 · High Court

citing judgments

The reassessment proceedings are invalid if the required sanction under Section 151 of the Income Tax Act is not obtained from the statutorily designated authority or if the approval is granted mechanically without due satisfaction. Approval by a higher authority cannot substitute the satisfaction of the authority specified in Section 151.

Judgments citing sanctioning authority

Akash Hareshkumar Jain, Kolhapur vs. DCIT Circle 1, Kolhapur

In the result, the appeal filed by the assessee is allowed

ITA 1934/PUN/2024[2018-19]Status: DisposedITAT Pune24 Feb 2025AY 2018-19

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2018-19

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Ramnath P Murkunde

Section 10(38)Section 132Section 147Section 148Section 153CSection 69A

order as well as the notice are issued on 7th April 2022, both have been issued beyond a period of three years. Therefore, the sanctioning authority has to be the PCCIT as provided under Section 151 (ii) of the Act. The proviso to Section 151 has been inserted only with

Hareshkumar Dungarmal Jain, Kolhapur vs. DCIT, Circle 1, Kolhapur

In the result, the appeal filed by the assessee is allowed

ITA 1933/PUN/2024[2018-19]Status: DisposedITAT Pune24 Feb 2025AY 2018-19

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2018-19

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Ramnath P Murkunde

Section 10(38)Section 132Section 147Section 148Section 153CSection 69A

Sanjay Gulabchand Gupta, Nagpur vs. Assistant Commissioner of Income Tax, Circle-4, Nagpur

In the result, appeal by the assessee stands dismissed

ITA 210/NAG/2023[2017-18]Status: DisposedITAT Nagpur14 Feb 2025AY 2017-18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Smt. Veena AgrawalFor Respondent: Shri Abhay Y. Marathe

Section 143(2)Section 54Section 54F

permissible for mix use same as in R2 zone. Copy of both Development control rules are attached for your ready reference. Accordingly, Local Sanctioning Authority who sanctions the map, has sanctioned it for residential cum commercial use. Accordingly the residential portion was sanctioned. Thus this cannot be a ground

Income Tax Officer, Ayakar Bhavan vs. Sukaniya Properties Pvt Ltd, Mumbai

In the result, appeal of the assessee is allowed and that of the

ITA 3711/MUM/2024[2008-09]Status: HeardITAT Mumbai14 Feb 2025AY 2008-09

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri Dharmesh Shah & Mitali Parekh, A/RsFor Respondent: Shri Bhangepatil Pushkaraj Ramesh, Sr. D/R

Section 147Section 148Section 150(1)Section 150(2)Section 250Section 68

APPELLATE TRIBUNAL I.T.A. No. 3309/Mum/2024 I.T.A. No. 3711/Mum/2024 Assessing Officer is prima facie evidence of non-application of mind on the part of the sanctioning authority while granting the sanction.” (emphasis supplied by us) 5.5. From the aforesaid proforma, it is also evident that the question No.11 mandate

M/S. Sukaniya Properties, Pvt. Ltd, Mumbai vs. DCIT, Central Circle -3(4), Mumbai

In the result, appeal of the assessee is allowed and that of the

ITA 3309/MUM/2024[2008-09]Status: HeardITAT Mumbai14 Feb 2025AY 2008-09

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri Dharmesh Shah & Mitali Parekh, A/RsFor Respondent: Shri Bhangepatil Pushkaraj Ramesh, Sr. D/R

Section 147Section 148Section 150(1)Section 150(2)Section 250Section 68

Income Tax on the part of the 7 Assessing Officer is prima facie evidence of non-application of mind on the part of the sanctioning authority while granting the sanction.” (emphasis supplied by us) 5.5. From the aforesaid proforma, it is also evident that the question No.11 mandate

Sushila Choudhary, Jaipur vs. Income Tax Officer, NFAC, Delhi

ITA 638/JPR/2024[2013-14]Status: DisposedITAT Jaipur12 Feb 2025AY 2013-14

For Appellant: Shri Nikhilesh Katariya, C.AFor Respondent: Shri Dinesh Badgujar, Addl.CIT (Thr. V.C.)

Section 139(1)Section 144BSection 147Section 148Section 292BSection 69A

आयकर अपीलीय अधिकरण, जयपुर न्यायपीठ, जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, "B" JAIPUR डा० एस. सीतालक्ष्मी, न्यायिक

Rekha Chandrakant Padalkar, Kandivali (East) vs. Income Tax Officer 42(3)(2), Mumbai

Appeal is allowed

ITA 6554/MUM/2024[2017-18]Status: DisposedITAT Mumbai12 Feb 2025AY 2017-18

Bench: Smt. Beena Pillai (Jm) & Shri Omkareshwar Chidara (Am) Rekha Chandrakant Padalkar Ito 42(3)(2) 701/702 B Wing, Gokul Kautilya Bhavan Paradise, Thakur Complex Vs. Bandra Kurla Kandivali East, Mumbai Complex, Bandra 400 101. East, Mumbai-51. Pan : Awdpp8597Q Appellant Respondent

For Appellant: Shri Nihar Ranjan SamalFor Respondent: Shri Dinar Prakash Daptari

Section 147Section 148Section 148ASection 250Section 50CSection 54

three years exceeded but the Ld. AO has taken approval of Principal Commissioner of Income Tax and not the approval of PCCIT. The sanctioning authority to give approval beyond three years is Principal Chief Commissioner of Income Tax u/s. 151(ii) of the Act for the assessment year under consideration ... Coordinate Bench of the ITAT, Mumbai in the case of Manish Financial (ITA No. 5055/Mum/2024). In this case, it was held that the sanctioning authority to accord approval for reopening the case is, before three years power is vested with Principal Commissioner of Income Tax and after three years, approval

M/S. Arthbharti Nagari Sahakari Patsanstha Maryadit, Latur vs. ITO, Ward-1, Latur

In the result, appeal of the Assessee is Partly Allowed

ITA 1848/PUN/2024[2018-19]Status: DisposedITAT Pune10 Feb 2025AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1848/Pun/2024 िनधा"रण वष" / Assessment Year: 2018-19 M/S.Arthbharti Nagari Sahakari V The Income Tax Officer, Patsanstha Maryadit, S Ward-1, Latur. Adarsh Colony, Old Ausa Road, Latur – 413512. Pan: Aabaa2265P Appellant/ Assessee Respondent / Revenue Assessee By Shri Bhuvanesh Kankani – Ar Revenue By Shri Manoj Tripathi - Dr Date Of Hearing 12/12/2024 Date Of Pronouncement 10/02/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] For Assessment Year 2018-19Dated 24.07.2024 Passed U/Sec.250 Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal : “1. Without Prejudice To Other Grounds & On The Facts & Circumstances Prevailing In The Case & As Per Provisions & Scheme Of The Income-Tax Act, 1961 ('The Act') It Be Held That The Assessment Proceedings So Completed Are Invalid Since The Addition Is Made On An Issue Different Than That For Which Case Was Re-Opened. Since, The Issue Of Re-Opening Did Not Survive The Assessment Proceedings Becomes Void-Ab-Initio. Accordingly, The Assessment Proceedings So Initiated & Completed Be Kindly Annulled & Appellant Be Granted Just & Proper Relief In This Respect.

Section 139(1)Section 147Section 148Section 148ASection 151Section 151ASection 250Section 80P

that the Assessment Year ("AY") is 2018-19 and, therefore, since more than three years have expired from the end of the assessment year, Sanctioning Authority under section 151(ii) of the Act should be the Principal Chief Commissioner of Income Tax ("PCCIT") and not the PCIT. Mr. Gandhi says

Mr. Ramlal G. Suthar, Mumbai vs. Income Tax Officer Ward, (2)(3), Mumbai

In the result, the appeal in ITA No

ITA 3224/MUM/2024[2017-18]Status: DisposedITAT Mumbai27 Jan 2025AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarmr. Ramlal G Suthar Vs Ito, Ward 10(2)(3), Mumbai Room No.212, 2Nd Floor, Aayakar A/704, Riddhi Siddhi Complex Near S.T. Stand, M.G. Road, Bhavan, M.K. Road, Mumbai-400 Sukarwadi, Borivali (E), 020 Mumbai-400 066 Pan :Afvpm2258J Appellant Respondent

For Appellant: Shri Hitesh JainFor Respondent: Shri Balasaheb Nagve (SR DR)

Section 144BSection 147Section 148Section 148ASection 151Section 250Section 50C(1)Section 56(2)Section 56(2)(vii)

issuance of notices under Section 148 for assessment year 2017-18. In alleged year, the Pr. CIT-2, Mumbai, acted as the sanctioning authority under Section 151 of the Act. However, the question of whether the appropriate authority sanctioned the notices, as required under Section ... notice and the subsequent assessment order were deemed invalid. Applying the same rationale here, it is evident that for alleged assessment year, the sanctioning authority failed to comply with the specific requirements of Section 151(ii) of the Act. Since the notices were issued under the new regime but lacked

Pradeep Kumar Agrawal, Dhamtari vs. Income Tax Officer, Ward-Dhamtari, Dhamtari

ITA 160/RPR/2024[2017-18]Status: DisposedITAT Raipur16 Jan 2025AY 2017-18

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 158, 159 & 160/Rpr/2024 (िनधा"रण वष" Assessment Year: 2015-16, 2016-17 & 2017-18)

For Appellant: Shri Sunil Kumar Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 143(2)Section 143(3)Section 147Section 148Section 250Section 44ASection 69

approval granted u/s 151(2) cannot be held as invalid for the reason that there was no the application of mind by the sanctioning authority. We, thus, unable to persuade and concur with the contention raised by the Ld. AR, consequently, ground no. 1 & 4 of the present appeal

Pradeep Kumar Agrawal, Dhamtari vs. Income Tax Officer, Ward-Dhamtari, Dhamtari

ITA 159/RPR/2024[2016-17]Status: DisposedITAT Raipur16 Jan 2025AY 2016-17

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 158, 159 & 160/Rpr/2024 (िनधा"रण वष" Assessment Year: 2015-16, 2016-17 & 2017-18)

For Appellant: Shri Sunil Kumar Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 143(2)Section 143(3)Section 147Section 148Section 250Section 44ASection 69

Pradeep Kumar Agrawal, Dhamtari vs. Income Tax Officer, Ward-Dhamtari, Dhamtari

ITA 158/RPR/2024[2015-16]Status: DisposedITAT Raipur16 Jan 2025AY 2015-16

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 158, 159 & 160/Rpr/2024 (िनधा"रण वष" Assessment Year: 2015-16, 2016-17 & 2017-18)

For Appellant: Shri Sunil Kumar Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 143(2)Section 143(3)Section 147Section 148Section 250Section 44ASection 69

Davos International Fund, Mumbai vs. Assistant Commissioner of Income Tax (International Taxation)-2(1)(1), Mumbai

Appeal of the assessee is partly allowed

ITA 1190/MUM/2024[2018-19]Status: DisposedITAT Mumbai13 Jan 2025AY 2018-19

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am

For Appellant: Shri Vijay Mehta / Shri DhavalFor Respondent: Shri Krishna Kumar, Sr. DR

Section 132Section 147Section 148Section 148ASection 149Section 149(1)Section 151Section 68

Viswanadh Kandula, Hyderabad vs. DCIT., Circle-6(1), Hyderabad

In the result, appeals of the assessee for the A

ITA 1085/HYD/2024[2018-19]Status: DisposedITAT Hyderabad07 Jan 2025AY 2018-19

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.1084 To 1088 & 1027/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2014-15 To 2019-20) M/S Ace Tyres (P) Ltd Vs. Acit Hyderabad Central Circle 1(2) Pan:Aadca2210N Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Prasad, Ca राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 02/09/2025 घोषणा की तारीख/Pronouncement: 24/09/2025 आदेश/Order Per Vijay Pal Raothese Six Appeals By The Assessee Are Directed Against The Six Separate Orders Dated 29/05/2025, 30/05/2025, 04/06/2025, 096/06/2025, 17/06/2025 & 14/07/2025 Of The Learned Cit (A)-11, Hyderabad Arising From The Assessment Order Passed U/S 143(3) R.W.S. 147 Of The Act, Pursuant To The Search & Seizure Operations U/S 132 Of The Act, Dated 04/01/2023 In Case Of Exel Group Of Companies Including The Assessee For The A.Ys 2014-15 To 2019-20 Respectively. Since Common Issues Are Raised In These Group Of Six Appeals Arising From Same Facts & Search & Seizure Operation, Therefore, For The Sake Of Convenience, All Page 1 Of 78

For Appellant: Shri M.V.Prasad, CAFor Respondent: : Dr. Sachin Kumar, Sr. AR

Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

case of approval. The learned Counsel for the assessee has submitted that in the case of the assessee neither the Assessing Officer nor the sanctioning authority has given any specific reasons for coming to the conclusion that it was a fit case for issuing notice ... would by no means suffice the statutory requirement as contemplated in Sec. 151 of the Act, i.e, satisfaction on the part of the sanctioning authority, on the reasons recorded by the A.O, that it is a fit case for issuance of a notice u/s 148 of the Act. As provided

Jbn Impex Pvt. Ltd., New Delhi vs. ITO, Ward 13(3), New Delhi

In the result, both these appeals are allowed

ITA 501/DEL/2024[2017-18]Status: DisposedITAT Delhi03 Jan 2025AY 2017-18

Bench: Shri Mahavir Singh, Hon’Ble & Shri Sanjay Awasthiआ.अ.सं/.I.T.A Nos.501 & 502/Del/2025 िनधा"रणवष"/Assessment Years:2015-16 & 2017-18 बनाम Trishul Homes & Infrastructure Dcit, Private Limited, Vs. Central Circle-31, Delhi. 101-102, 3 Tolstoy Marg, Connaught Place, New Delhi. Pan No.Aaect5592R अपीलाथ" Appellant ""यथ"/Respondent

Section 144BSection 153ASection 153BSection 153DSection 250

subject. 2.1 The Ld. DR mentioned that the approval had been obtained as per law and it is not necessary for the sanctioning authority to mandatorily examine the seized material etc. over a period of several days before granting approval. The Ld. DR relied on the orders of the authorities ... very carefully considered one and such careful consideration has to be visible from the paper trail between an AO and the sanctioning authority. In this case, not only is the approval given on the same date but it is also given in a bunched-up manner. Respectfully, following

Cosmic Informatics Pvt. Ltd., New Delhi vs. ACIT Central Circle - 2, New Delhi

In the result, appeal of the Revenue in appeal No

ITA 2444/DEL/2024[2017-18]Status: DisposedITAT Delhi02 Jan 2025AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

section 151(1) is granted." The aforesaid could not be regarded as valid satisfaction inasmuch the aforesaid note: (a) clearly indicate that the sanctioning authority simply perused the reasons, with looking into the records; and (b) does not show any application of mind which, it is submitted, is sine ... which only leads to the inescapable conclusion that there was, in reality, no perusal of assessment record and independent application of mind by the sanctioning authority (les) for according approval. The Orissa High Court in the case of ACTT vs. Serajuddin & Co. (2023) 454 ITR 312 (Ori), while disapproving

Cosmic Informatics Pvt. Ltd., New Delhi vs. ACIT Central Circle - 2, New Delhi

In the result, appeal of the Revenue in appeal No

ITA 2443/DEL/2024[2013-14]Status: DisposedITAT Delhi02 Jan 2025AY 2013-14

Section 143Section 143(3)Section 147Section 148Section 151

Ashok Amratlal Shah, Mumbai vs. ITO Ward 42(1)(1), Mumbai

In the result, the appeals of the assessee bearing ITA Nos

ITA 4286/MUM/2024[2015-16]Status: DisposedITAT Mumbai31 Dec 2024AY 2015-16

Bench: Shri.B.R. Baskaran & Shri Anikesh Banerjee- A.Y. 2015-16 - A.Y. 2016-17 - A.Y. 2017-18

For Appellant: Ms. Kinjal BhutaFor Respondent: Shri Ram Krishn Kedia (SR DR)

Section 115BSection 132Section 139(1)Section 144BSection 147Section 148Section 148ASection 149Section 151Section 151A

Notice u/s 148 as per old regime 23/06/2021 20/06/2021 22/06/2021 (deemed to be show cause notice u/s. 148A(b) of the Act). Sanctioning authority u/s 151 for the PCIT, Mumbai-17 JCIT, Range JCIT, Range above-mentioned notice u/s 148 (old 32(1), Mumbai 32(1), Mumbai regime) Issue Letter ... assessee to the 31/05/2022 31/05/2022 31/05/2022 above issue letter. Order u/s. 148A(d) and notice u/s 148 30/06/2022 30/06/2022 30/06/2022 (under new law) Sanctioning Authority of notice issued PCIT-2, Mumbai PCIT-2, Mumbai PCIT-2, Mumbai u/s. 148 (under new regime) 6.Notices under Section 148 of the Act were

Amit Khatri, Sonipat vs. ITO, Ward 1, Sonipat

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

ITA 2430/DEL/2023[2012-13]Status: DisposedITAT Delhi18 Dec 2024AY 2012-13

Bench: Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.2430/Del/2023 िनधा"रणवष"/Assessment Year: 2012-13 बनाम Amit Khatri Income Tax Officer Ward No.30, Garhi Bhraman, Vs. Ward-1, Sonipat, Haryana. Sonipat, Haryana. Pan No. Bdspk3438G अपीलाथ" Appellant ""यथ"/Respondent

Section 147Section 148Section 151

Delhi (supra) in which reopening of the assessment in identical circumstances was held to be bad in law and sanction accorded by the Sanctioning Authority was also found invalid, therefore, reopening of the assessment was quashed. In the present case, the Learned Counsel for the Assessee has pointed-out that

Sky Blue Infotech Pvt Ltd, New Delhi vs. ITO Ward - 23(4), New Delhi

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

ITA 438/DEL/2020[2010-11]Status: DisposedITAT Delhi13 Dec 2024AY 2010-11

Bench: Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.438/Del/2020 िनधा"रणवष"/Assessment Year: 2010-11 बनाम Sky Blue Infotech Pvt. Ltd. Income Tax Officer 206, Hans Bhawan, 1, Vs. Ward-23(4), Bahadurshah Zafar Marg, Room No.246, C.R. Bldg., New Delhi. I.P. Estate, New Delhi. Pan No. Aalcs1584K अपीलाथ" Appellant ""यथ"/Respondent

Section 147Section 148Section 151Section 271(1)(c)Section 68Section 69C

Delhi (supra) in which reopening of the assessment in identical circumstances was held to be bad in law and sanction accorded by the Sanctioning Authority was also found invalid, therefore, reopening of I.T.A. No. 438/Del/2020 the assessment was quashed. In the present case, the Learned Counsel for the Assessee