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Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI
Before: SHRI SATBEER SINGH GODARA
Date of hearing 03.06.2025 Date of pronouncement 03.06.2025 ORDER This assessee’s appeal for assessment year 2011-12, 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/250/2024-25/1073622901(1), dated 24.02.2025 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 at the outset that there is hardly any much a need for the tribunal to delve with the relevant factual matrix at length so far as the assessee’s assessing for having deposited amount of Rs.46,58,756/- in ICICI bank account is concerned. This is for the precise reason that the learned departmental authorities already appear to have assessed Smt. Gurinder Maingi Thaman for the very amount in the impugned assessment year 2011-12 as her learned Assessing Officer had recorded the reasons of reopening for the very assessment year.
This being the clinching factual position, it is concluded that the learned lower authorities could not have treated the above deposits as the assessee’s income liable to be taxed. The impugned reopening stands quashed.