ASSISTANT COMMISSIONER OF INCOME TAX, DELHI vs. VERTEX INTERNATIONAL PRIVATE LIMITED, DELHI

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “B”: NEW DELHI BEFORE MS MADHUMITA ROY, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No. 204/Del/2026 (A.Y 2015-16) Assistant Commissioner of Vs. Vertex international Income Tax, Room No. Private Limited 192A, First Floor, C. R. 3682/1 2nd Floor Shabi Building, ITO, New Delhi Market, Mori Gate, Central Delhi, Delhi (Appellant) (Respondent) PAN: AAECV1415D

C.O No. 173/Del/2026 in ITA No. 204/Del/2026 (A.Y 2015-16) Vertex international Private Vs. Assistant Commissioner Limited. 3682/1 2nd Floor of Income Tax Shabi Market, Mori Gate, Room No. 192A, First Central Delhi, Delhi Floor, C. R. Building, ITO, New Delhi (Appellant) (Respondent) PAN: AAECV1415D Assessee by : Ms. Rano Jain, Adv and Ms. Mansi Jain, Adv Revenue by: Shri Rajesh Mahajan, CIT (DR)

Date of Hearing 02/06/2026 Date of pronouncement 04/08/2026 O R D E R PER MADHUMITA ROY, J. M.: The instant appeal filed by the Revenue and Cross

Objection filed by the Assessee are directed against the order

dated 25.11.2025 passed by the Ld. Commissioner of Income-

tax (Appeals)/National Faceless Appeal Centre, Delhi

[hereinafter referred to as the Ld. CIT(A)] under Section 250 of

the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’)

arising out of the Assessment Order dated 30.05.2023 passed

2 ITA No. 204 & C.O No. 173/Del/2026 Vertex International (P) Ltd. by the Assessment Unit, Income-tax Department (hereinafter

referred to as ‘the ld. AO’) under Section 147 read with Section

144B of the Act for Assessment Year 2015-16.

validity of reopening proceedings under Section 147 by issuing

notice under Section 148 of the Act, a copy whereof has been

annexed to the paper book filed before us. The reopening of

assessment has been done in respect of A.Y. 2015-16 by

issuing notice under Section 148 of the Act as above. The

assessee’s counsel joins the issue here to this effect that as per

the concession on behalf of the Department recorded in para

19(f) in the case of Union of India and ors Vs Rajeev Bansal 469

ITR 46 (SC) the impugned notice under Section 148 of the Act

issued in assessee’s case for reopening is liable to be struck

down at threshold. Clause (f) reads as under:

“(f) The revenue concedes that for A.Y. 2015-16 all notices issued on or after April 1,2021 will have to be dropped as they will not fall for completion during the period prescribed under the Taxation and under Laws (Relaxation and Amendment of certain provisions) Act, 2020.” Undisputedly, in the case in hand notice under Section 148 of

the Act was issued on 29.06.2021. Thus, having regard to the

above factual aspect of the matter, the entire reassessment Page | 2

3 ITA No. 204 & C.O No. 173/Del/2026 Vertex International (P) Ltd. proceedings isfound to be not sustainable and therefore,

quashed.

dismissing the entire proceeding initiated under Section 147 of

the Act, the Appeal preferred by the Revenue becomes

infructuous and thus, dismissed.

the appeal filed by the Revenue is dismissed.

Order pronounced in the open court on 04/08/2026.

Sd/- Sd/-

(MANISH AGARWAL) (MADHUMITA ROY) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 04/08/2026 R. Naheed, Sr PS Copy forwarded to 1. Applicant 2. Respondent 3. CIT 4. CIT (A) 5. DR:ITAT ASSISTANT REGISTRAR ITAT, New Delhi

4 ITA No. 204 & C.O No. 173/Del/2026 Vertex International (P) Ltd.