MANISH CHANDULAL JOBANPUTRA,RAJKOT vs. INCOME TAX OFFICER, RAJKOT

ITA 414/RJT/2026Status: DisposedITAT Rajkot22 October 2026AY 2020-215 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were bad in law due to a defective approval under section 151 of the Act. The Tribunal noted that the approval provided by the revenue was neither digitally nor manually signed. It respectfully followed the binding precedent of the Coordinate Bench in M/s Aditya Plastic (supra), which had also quashed the assessment order on similar grounds, citing the lack of a valid signature on the approval under section 151 and the Allahabad High Court's decision in Vikas Gupta. The Tribunal found no reason to deviate from this precedent as there was no change in facts or law, and the revenue could not produce any material to controvert the earlier findings. Therefore, the assessment order framed by the AO was quashed. The appeal of the assessee was allowed.

What were the facts?

The assessee, Manish Chandulal Jobanputra, filed an appeal against the order dated 04.02.2026 passed by the National Faceless Assessment Centre, Delhi/Commissioner of Income Tax (Appeals) (NFAC/CIT(A)). This order arose from a reassessment order passed by the Assessing Officer (AO) under section 147 of the Income-tax Act, 1961, dated 07.03.2025, for the assessment year 2020-21. The AO's reassessment proceedings were initiated based on a defective approval under section 151 of the Act. The assessee contended that the approval lacked a manual or digital signature, rendering the reassessment proceedings invalid. The revenue relied on the AO's order.

What were the issues?

1. Whether the reassessment proceedings initiated by the Assessing Officer under section 147 of the Income-tax Act, 1961, are bad in law due to a defective approval under section 151 of the Act? Assessee's Contention: The assessee argued that the approval under section 151 of the Act was neither manually nor digitally signed. Consequently, the reassessment order based on this defective approval is bad in law and should be quashed. The assessee relied on the ITAT Rajkot Bench's decision in M/s Aditya Plastic (ITA No. 185/Rjt/2024) and the Allahabad High Court's judgment in Vikas Gupta ((2022) 142 taxmann.com 253 (Allahabad HC)). Revenue's Contention: The revenue relied on the order passed by the Assessing Officer.

Which sections of the Income-tax Act were involved?

Section 147,Section 151,Section 250,Section 148

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC”

Before: Dr. Arjun Lal Saini

For Respondent: Shri Ganesh Iyer, Sr. DR
Hearing: 15/10/2026Pronounced: 22/10/2026

Per, Dr. Arjun Lal Saini, AM: Captioned appeal filed by the assessee, pertaining to assessment year (AY) 2020-21, is directed against the order passed under section 250 of the Income-tax Act, 1961 [hereinafter referred to as ‘the Act’] dated 04.02.2026 by the National Faceless Assessment Centre, Delhi/ Commissioner of Income Tax (Appeals) [hereinafter referred to as ‘Ld.CIT(A)/NFAC’], which in turn arises out of an assessment order passed by the Asse

The order continues below.

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