RNAM FINLEASE PVT LTD,DELHI vs. ITO WARD 20(3), DELHI

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ITA 3114/DEL/2026Status: DisposedITAT Delhi15 July 2026AY 2009-102 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 the approval from the prescribed authority under section 151 was mechanical, lacking independent application of mind. This decision was based on a Supreme Court ruling.

What were the facts?

The assessee's appeal for AY 2009-10 was against an order involving proceedings under section 147. The primary issue was the validity of the reopening of assessment.

What were the issues?

The key legal issue was the validity of the reopening of assessment due to a flawed approval process by the prescribed authority.

Which sections of the Income-tax Act were involved?

Section 147,Section 151

AI-generated summary — verify with the full judgment below

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

Before: SHRI SATBEER SINGH GODARA

Hearing: 29.06.2026Pronounced: 29.06.2026

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER ITA No.3114/Del/2026 Assessment Year: 2009-10 M/s. RNAM FINLEASE PVT Vs. Income Tax Officer, LTD., Ward-20(3), AG-5, Main Ring Road, New Delhi Shalimar Bagh, New Delhi PAN: AAACR3761N (Appellant) (Respondent) Assessee by Sh. Abhishek Mathur, Adv. Department by Sh. Manoj Kumar, Sr. DR Date of hearing 29.06.2026 Date of pronouncement 29.06.2026 ORDER This assessee’s appeal for assessment year 2009-10, arises against the Commissioner of Income Tax (Appeals)/Addl./JCIT(A), Mysore’s order dated 30.01.2026 having DIN & Order No. ITBA/APL/S/250/2025-26/1085358194(1), dated 30.01.2026, involving proceedings under section 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused. 2. It emerges during the course of hearing that there arises the first and foremost issue of the validity of the impugned reopening

ITA No.3114/Del/2026

itself, which goes to the root of the matter. This is for the precise reason that the learned counsel representing assessee has invited our attention to the prescribed authority’s section 151 approval to the Assessing Officer’s reopening proposal, wherein, he has recorded “I am satisfied………” than having applied its independent mind thereupon (page -9 in paper-book) 3. Thus, I am of the considered view that the impugned reopening itself is invalid since based on a mere mechanical approval of the said prescribed authority in light of CIT Vs. S. Goyanka Lime and Chemical Pvt. Ltd. (2015) 64 taxmann.com 313 (SC) to quash the same in very terms. Ordered accordingly. All other pleadings on merits stand rendered academic. 4. This assessee’s appeal is allowed. Order pronounced in the open court on 29th June, 2026 Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER Dated: 15th July, 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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