M/S REINFORCE RECRUITER PRIVATE LIMITED,NEW DELHI vs. INCOME TAX OFFICER, WARD 21(1), DELHI

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ITA 7914/DEL/2025Status: DisposedITAT Delhi07 July 2026AY 2012-133 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 and lacked independent application of mind. This decision was based on a Supreme Court ruling.

What were the facts?

The assessee's appeal for AY 2012-13 was heard by the ITAT. The primary issue raised 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 151

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH: ‘E’ NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI M. BALAGANESH

Hearing: 01.07.2026Pronounced: 01.07.2026

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘E’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI M. BALAGANESH, ACCOUNTANT MEMBER ITA No.7914/Del/2025 Assessment Year: 2012-13 M/s. Reinforce Recruiter Vs. Income Tax Officer, Pvt. Ltd., Ward -21(1), 116A, 1st Floor, Somdutt New Delhi Chamber-1, 5, Bhikaji Cama Place, New Delhi PAN: AAECR5711L (Appellant) (Respondent) Assessee by Sh. Ankur Agarwal, CA Department by Sh. Tarun Sharda, Sr. DR Date of hearing 01.07.2026 Date of pronouncement 01.07.2026 ORDER PER SATBEER SINGH GODARA, JM This assessee’s appeal for assessment year 2012-13, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1081815459(1), dated 16.10.2025 involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused.

ITA No. 7914/Del/2025

2.

It emerges during the course of hearing that there arises the first and foremost issue of the validity of the impugned reopening 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. 3. Thus, we are 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 1st July, 2026 Sd/- Sd/- (M. BALAGANESH) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 7th July, 2026. RK/- Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 2 | P a g e

ITA No. 7914/Del/2025

5.

DR Asst. Registrar, ITAT, New Delhi

3 | P a g e

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