SANJAY RAJPUT,DELHI vs. INCOME TAX OFFICER, WARD 43(1), DELHI, DELHI
In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.
What did the Tribunal hold?
The Tribunal held that the reopening of assessment was invalid because the approval obtained from the prescribed authority under section 151 was mechanical and lacked independent application of mind. This decision was based on the Supreme Court ruling in CIT vs. S. Goyanka Lime and Chemical Pvt. Ltd.
What were the facts?
The assessee's appeal for AY 2012-13 was against the CIT(A)/NFAC order. The primary issue raised was the validity of the reopening proceedings initiated by the Assessing Officer.
What were the issues?
The key legal issue was the validity of the reopening of assessment due to a defective approval from the prescribed authority.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI
Before: SHRI SATBEER SINGH GODARA
IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER ITA No.3765/Del/2026 Assessment Year: 2012-13 Sh. Sanjay Rajput, Vs. Income Tax Officer, RZ-49, Sitapur, Part-1, Gali Ward-43(1), No. 08, Dadri, Delhi South West Delhi, Delhi -110045 PAN: AGHPR4334F (Appellant) (Respondent) Assessee by Sh. Suresh Gupta, CA Department by Sh. Manoj Kumar, Sr. DR
Date of hearing 01.06.2026 Date of pronouncement 01.06.2026 ORDER 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/250/2025-26/1086167613(1), dated 18.02.2026 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. 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.3765/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. 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 1st June, 2026 Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER Dated: 29th June, 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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