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Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI
Before: SHRI SATBEER SINGH GODARA
Date of hearing 14.05.2025 Date of pronouncement 14.05.2025 ORDER This assessee’s appeal for assessment year 2009-10, arises against the Commissioner of Income Tax (Appeals) [in short, the “CIT(A)”], Ghaziabad’s order dated 18.01.2019 passed in case no. 819315031220617, dated 18.01.2019, involving proceedings under section 144/147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). 2. 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 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 “yes, it is a fit case”.