M/S. AMZEN TECHNOLOGIES PVT. LTD,NEW DELHI vs. ITO, WARD -2(3), DELHI

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ITA 5049/DEL/2026Status: DisposedITAT Delhi23 July 2026AY 2011-122 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 reopening of assessment was invalid because it was initiated solely for the purpose of verification. The court quashed the impugned reopening based on the assessee's contention and supporting case law.

What were the facts?

The assessee's appeal for AY 2011-12 arose from reassessment proceedings initiated by the AO. The AO's primary reason for reopening was that transactions done by the assessee company remained unverifiable or undisclosed.

What were the issues?

The key issue was the validity of the reassessment proceedings initiated by the Assessing Officer. The tribunal examined whether the reasons provided for reopening were legally sufficient.

Which sections of the Income-tax Act were involved?

Section 147,Section 143(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘SMC’, NEW DELHI

Before: Sh. Satbeer Singh Godara

For Appellant: Shri S. Krishnan, Adv
Hearing: 08.07.2026Pronounced: 08.07.2026

This assessee’s appeal for Assessment Year 2011-12,

arises against the CIT(A)/NFAC, Delhi’s DIN & Order No.

ITBA/NFAC/S/250-2025-26/1086858883(1) dated 5.03.2026, in

proceedings u/s 147/143(3) of the Income Tax Act, 1961 (in

short “the Act”).

2.

Heard both the parties. Case file perused.

3.

Coming to the first and foremost issue of validity of

impugned reopening itself, learned counsel invites the

tribunal’s attention to the detailed discussion at page no. 1 of

the assessment order itself that he had set into motion on the

same for the reasons that “transaction done by the assessee

company remains unverifiable or it can be said the same has

not been disclosed to the department”. This clinching factual

position has gone unrebutted from the Revenue side.

4.

The assessee’s case therefore is that since the impugned

reopening initiated for the purpose of verification, the same

could not be held as a valid one in the eyes of law as per

(2023) 123 taxmann.com 55 (Guj) Vijay R. Saghvi vs. ACIT.

This Tribunal accordingly reject the Revenue’s vehement

arguments supporting the same to quash the impugned

reopening is very terms.

5.

In the result, the appeal of the assessee is allowed.

Order Pronounced in the Open Court on 08/07/2026.

Sd/- (Satbeer Singh Godara) Judicial Member

Dated: 23/07/2026

SR BHATNAGAR

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