PUJA DINESH SINGH,RAJKOT vs. THE INCOME TAX OFFICER, PORBANDAR

ITA 928/RJT/2026Status: DisposedITAT Rajkot17 September 2026AY 2020-215 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were invalid because the approval under Section 151 was neither manually nor digitally signed, rendering it invalid. Consequently, the assessment order based on these invalid proceedings was quashed.

What were the facts?

The assessee's appeal pertains to AY 2020-21, challenging the reassessment proceedings initiated under Section 147 and subsequent additions. The assessee argued that the reassessment proceedings were invalid due to a lack of proper approval under Section 151.

What were the issues?

The primary issue was the validity of reassessment proceedings initiated without a proper and valid approval under Section 151 of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 151,Section 69A,Section 115BBE,Section 271AAC(1),Section 274

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC”

Before: Dr. Arjun Lal Saini

For Respondent: Shri Shishir Kumar, Ld. Sr. DR
Hearing: 30/07/2026Pronounced: 17/09/2026

Per, Dr. Arjun Lal Saini, AM: Captioned appeal filed by the assessee, pertaining to Assessment Year 2020-21, is directed against the order under section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by Commissioner of Income-tax (Appeals), National Faceless Appeal Centre (NFAC) Delhi, dated 02.06.2026, which in turn arises out of assessment order passed by the Assessing Officer u/s 147 of the Act, on 15.03.2025. 2. The Grounds of appeal raised by the assessee are as under:

“1. The Ld. CIT (A) er

The order continues below.

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