PURSHOTAM ANAND,DELHI vs. ITO WARD 49(1), DELHI

ITA 675/DEL/2026Status: DisposedITAT Delhi30 April 2026AY 2017-189 pages
AI SummaryAllowed

What were the facts?

The assessee's income tax return for AY 2017-18 was assessed under Section 147, with additions made for undisclosed cash deposits. The assessee challenged the assessment, primarily on the grounds of invalid approval for reassessment proceedings.

What did the Tribunal hold?

The Tribunal held that the approval for issuing the reassessment notice under Section 148 was not obtained from the competent authority as required by Section 151(ii) of the Act, as more than three years had elapsed from the end of the relevant assessment year. Consequently, the assessment order was quashed.

What were the issues?

Whether the reassessment proceedings were validly initiated when the approval for issuing the notice under Section 148 was obtained from an authority not specified in Section 151(ii) for cases where more than three years have elapsed from the end of the assessment year.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A,Section 151,Section 56(2)(ix),Section 69A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH “A”, DELHI

Before: SH. SUDHIR KUMAR

For Appellant: Adv. Sh. Rajeev Kumar, Adv
Hearing: 28/04/2026Pronounced: 30/04/2026

PER SUDHIR KUMAR, JUDICIAL MEMBER:

This appeal by the assessee is directed against the order of the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre, Delhi [hereinafter referred to as “NFAC”] vide order dated 28.11.2025 pertaining to A.Y. 2017-18 arising out the assessment order dated 13.04.2023 u/s.147r.w.s.144B of the Income-tax Act, 1961, (in short ‘the Act’).

2.

The assessee has raised the ground no, 2 on the approval which is as under: 2.That the order passed u/s 147 on 13-04-2023 as has ben upheld by Ld. CIT(A) on 28-11-25 become further non-est as also covered by M/s Twilight infrastructure (p) LTD vs. ITO (2024) S.C.C. online Delhi 330 because of gra

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 147

All 48,773 judgments and leading authorities on Section 147 →

Recent GST High Court judgments

Search GST case law →