DEEPALI DESIGNS AND EXHIBITS PVT. LTD,NEW DELHI vs. DCIT, CENTRAL CIRCLE-17, DELHI
Before: SHRI SATBEER SINGH GODARA & SHRI MANISH AGARWALAssessment Year: 2012-13 M/s. Deepali Designs & Exhibits Pvt. Ltd., GN-06, Shivaji Enclave, Rajouri Garden, New Delhi Vs. DCIT, Central Circle-17, Delhi PAN: AABCD5680K (Appellant)
PER SATBEER SINGH GODARA, JM
This assessee’s appeal for assessment year 2012-13, arises against the Commissioner of Income Tax (Appeals)-27 [in short, the “CIT(A)”], New Delhi’s order dated 31.03.2022 passed in CIT(A),
Delhi-27/10224/2019-20, involving proceedings under section 143(3)/147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
2. Heard both the parties. Case file perused.
Assessee by Ms. Ananya Kapoor, Adv.
Department by Sh. Rajesh Kumar Dhanesta, Sr.DR
Date of hearing
26.05.2025
Date of pronouncement
26.05.2025
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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 the assessee has invited our attention to the prescribed authority’s section 151 approval to the Assessing Officer’s reopening proposal, wherein, he has recorded “perused reasons, satisfied fit case………………”. 4. 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. 6. This assessee’s appeal is allowed. Order pronounced in the open court on 26th May, 2025 (MANISH AGARWAL) JUDICIAL MEMBER
Dated: 26th May, 2025. 3 | P a g e
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