ASSISTANT COMMISSIONER OF INCOME TAX, CIVIC CENTRE vs. SATYA NARAYAN GUPTA, DELHI

ITA 2064/DEL/2026Status: DisposedITAT Delhi19 August 2026AY 2013-1410 pages
AI SummaryDismissed

What were the facts?

The Assessing Officer reopened the assessee's assessment under Section 147 based on an approval granted by the Principal Commissioner of Income Tax. This approval was part of a general order for 111 cases, without specific application of mind to the assessee's case.

What did the Tribunal hold?

The Tribunal held that the approval for reopening the assessment was granted mechanically and lacked due application of mind, rendering it invalid. Consequently, the assumption of jurisdiction under Section 147 and the reassessment proceedings were quashed.

What were the issues?

The primary issue was the validity of the approval granted by the Principal Commissioner for reopening the assessment under Section 151, and whether it was granted mechanically.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 151,Section 292BC

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH “B”: NEW DELHI

Before: SHRI M. BALAGANESH & SHRI SUDHIR KUMAR

For Appellant: Adv. & Ms. Uma
Hearing: 21.07.2026Pronounced: 19.08.2026

Heard together (2 matters)

I.T.A. No. 2064/Del/2026
C.O. No. 156/Del/2026

Read from the judgment's own cause title. This page is filed under one of them.

PER M. BALAGANESH, A. M.:

This appeal of the Revenue arises out of the order passed by the Commissioner of Income Tax (Appeals) NFAC, Delhi [hereinafter referred to as ‘ld. CIT(A)’, in short] in Appeal No. 2064/Del/2026 for A.Y. 2013-14 dated 03.12.2025 which in turn arises

The order continues below.

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