ZYGONET SOLUTIONS PRIVATE LIMITED,ROHINI, DELHI vs. DCIT, CENTRAL CIRCLE 25, JHANDEWALA EXT, NEW DELHI

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ITA 4940/DEL/2026Status: DisposedITAT Delhi14 August 2026AY 2019-203 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the Assessing Officer's failure to quantify the escaped income in the reasons recorded for reopening vitiates the entire proceedings. Therefore, the reopening was quashed.

What were the facts?

The assessee challenged the validity of the reopening of assessment for the assessment year 2019-20. The primary contention was that the Assessing Officer's reasons for reopening failed to specify the exact amount of income that had allegedly escaped assessment.

What were the issues?

The key issue was the validity of the reopening of assessment due to the Assessing Officer's failure to specify the quantum of escaped income in the reasons recorded.

Which sections of the Income-tax Act were involved?

Section 147

AI-generated summary — verify with the full judgment below

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

Before: SHRI SATBEER SINGH GODARA

Hearing: 16.07.2026Pronounced: 16.07.2026

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER ITA No.4940/Del/2026 Assessment Year: 2019-20 ZYGONET SOLUTIONS PVT Vs. DCIT, LTD., Plot No. 24, First Central Circle-25, Floor, Block-D, Pocket-17, New Delhi Sector-3, Rohini, Sector-7, Northwest Delhi, Delhi PAN: AADCC7239D (Appellant) (Respondent)

Assessee by Sh. Nimesh Chotani, CA Department by Sh. Manoj Kumar, Sr. DR

Date of hearing 16.07.2026 Date of pronouncement 16.07.2026 ORDER This assessee’s appeal for assessment year 2019-20, arises against the Commissioner of Income Tax (Appeals) -29 [in short, the “CIT(A)”], Delhi’s order dated 26.02.2026 passed in case No. CIT(A), Delhi-29 10919/2018-19, involving proceedings under section 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused.

ITA No.4940/Del/2026

2.

The assessee/appellant herein canvasses its first and foremost legal ground challenging validity of the impugned reopening itself. This is for the precise reason that the learned counsel has invited the tribunal’s attention to the Assessing Officer’s reopening reasons herein recorded on 30.03.2023 nowhere specifying as to what exact amount of the assessee’s alleged taxable income liable to be assessed had escaped assessment. 3. The Revenue, on the other hand, draws strong support from the impugned reopening reasons that the tribunal ought to appreciate the totality of all the relevant facts than adopting a hyper technical approach in such an instance of the reopening reasons recorded by the Assessing Officer. 4. I have given my thoughtful consideration to the assessee’s and the Revenue’s respective vehement submissions. I find no reason to sustain the impugned reopening in light of Divyang Jayendrabhai Shah Vs. Assistant Commissioner of Income-tax Circle-1, (2026) 188 taxmann.com 793 (Guj.) as the learned Assessing Officer has admittedly failed to quantify the assessee’s

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ITA No.4940/Del/2026

income having escaped assessment in the reasons recorded by him which vitiates the entire proceedings itself. Quashed accordingly. All other remaining pleadings on merits between the parties stand rendered academic. 5. This assessee’s appeal is allowed. Order pronounced in the open court on 16th July, 2026 Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER Dated: 14th August, 2026. RK/- Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi

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