Loading judgment…
No AI summary yet for this case.
Income Tax Appellate Tribunal, DELHI BENCH: ‘B’ NEW DELHI
Before: SHRI SATBEER SINGH GODARA & SHRI MANISH AGARWAL
Assessment Year: 2012-13 Vs. Income Tax Officer, Siroo Fashions Pvt. Ltd., C/o- Kapil Goel, Adv, Ward-23(2), F-26/124, Sector-7, Rohini, New Delhi Delhi PAN: AALCS8232L (Appellant) (Respondent) Assessee by Dr. Kapil Goel, Adv. Department by Sh. Rajesh Kumar Dhanesta, Sr. DR Date of hearing 13.08.2025 Date of pronouncement 13.08.2025 ORDER
PER SATBEER SINGH GODARA, JM
This assessee’s appeal for assessment year 2012-13, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2024-25/1070971609(1), dated 06.12.2024 involving proceedings under section 147 r.w.s. 144 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused.
It emerges during the course of hearing that there arises the first and foremost issue of the validity of the impugned reopening itself, which goes to the root of the matter. This is for the precise reason that the learned counsel representing assessee has invited our attention to the prescribed authority’s section 151 approval to the Assessing Officer’s reopening proposal, wherein, he has recorded “I am satisfied……..”.