MADHU BALA,DELHI vs. ACIT CENTRAL CIRCLE-16, DELHI

ITA 1746/DEL/2026Status: DisposedITAT Delhi25 September 2026AY 2021-2211 pages
AI SummaryAllowed

What were the facts?

The assessee's case was reopened under Section 147 after a search operation. The assessee challenged the assessment order, arguing that the approval granted under Section 148B was vitiated due to vague reasons and lack of a live nexus.

What did the Tribunal hold?

The Tribunal held that the approval for reopening was granted based on vague information and a mechanical exercise of power, lacking a live nexus to the seized material. The notice and approval did not exhibit supporting material linking the seized documents to the escapement of income.

What were the issues?

Whether the approval granted for reopening the assessment under Section 148B was valid, considering the vagueness of reasons and lack of a live nexus between seized material and escapement of income.

Which sections of the Income-tax Act were involved?

Section 147,Section 143(3),Section 148B,Section 148,Section 149(1)(a),Section 132,Section 292BC

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH, DELHI

Before: SHRI ANUBHAV SHARMA & SHRI SANJAY AWASTHI

Hearing: 07.07.2026Pronounced: 25.09.2026

PER ANUBHAV SHARMA, JM:

This appeal is preferred by the assessee against the order dated 20.01.2026 of the Ld. CIT(A)-26, Delhi (hereinafter referred as Ld. First

P a g e | 2 Madhubala (AY: 2021-22) Appellate Authority or in short Ld. ‘FAA’) in DIN & Order No: ITBA/APL/S/250/2025-26/1084973272(1) arising out of the assessment order dated 26.03.2025 u/s 147 r.w.s 143(3) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) passed by the ACIT, CC-16, New Delhi, for AY: 2021-22. 2. Heard and perused the record. At the time of arguments ld. Counsel has argued on the legal issue whereby assesse has challenge

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 →