SIROO FASHIONS PVT LTD.,DELHI vs. ITO,WARD-23(2), NEW DELHI
Before: SHRI SATBEER SINGH GODARA & SHRI MANISH AGARWALAssessment Year: 2012-13 Siroo Fashions Pvt. Ltd., C/o- Kapil Goel, Adv, F-26/124, Sector-7, Rohini, Delhi Vs. Income Tax Officer, Ward-23(2), New Delhi PAN: AALCS8232L (Appellant)
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.
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
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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……..”. 3. Learned counsel’s case accordingly is that the impugned reopening itself is invalid since based on a mere mechanical approval of the said prescribed authority. We make it clear that the foregoing clinching fact of the competent authority’s mechanical approval has indeed gone unrebutted from the department side. 5. This assessee’s appeal is allowed. Order pronounced in the open court on 13th August, 2025 (MANISH AGARWAL) JUDICIAL MEMBER
Dated: 13th August, 2025. 3 | P a g e
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