SHRI. KRISHNA ENTERPRISES,BANGALORE vs. INCOME TAX OFFICER, WARD-7(2)(1), BANGALORE

ITA 523/BANG/2025Status: DisposedITAT Bangalore29 December 2025AY 2016-1722 pages
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What did the Tribunal hold?

The Tribunal held that for AYs 2016-17 and 2017-18, the approval was granted by the Principal Commissioner of Income Tax, whereas it should have been by the Principal Chief Commissioner of Income Tax as more than three years had elapsed from the end of the relevant assessment years. For AY 2014-15, a common approval for multiple parties was also deemed invalid due to a lack of application of mind.

What were the facts?

The assessee filed appeals against reassessment orders for AYs 2014-15, 2016-17, and 2017-18. The primary challenge was to the validity of the approval granted under Section 151 of the Income Tax Act for reopening the assessments.

What were the issues?

The key issue was whether the approval for reopening the assessment under Section 151 was obtained from the correct authority, considering the time elapsed since the end of the assessment year. Another issue was the validity of common approvals granted for multiple assessees.

Which sections of the Income-tax Act were involved?

Section 151,Section 147,Section 148,Section 148A

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Cases cited in this judgment(3)Show list

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Income Tax Appellate Tribunal, BBENCH : BANGALORE

Before: SHRI PRASHANT MAHARISHI, VICE – & SHRI SANDEEP SINGH KARHAIL

For Appellant: Shri Ravishankar, Advocate
For Respondent: Shri Subramanian, JCIT DR

PER PRASHANT MAHARISHI, VICE – PRESIDENT

1.

These are three appeals filed by Shri Krishna enterprises, Bangalore (Assessee/Appellant) for Assessment Year 2014-15, 2016-17 and 2017-18. 2. ITA No. 522/Bang/2025 is filed for Assessment Year 2014-15 against the Appellate Order passed by the National Faceless Appeal Centre, Delhi (the Ld. CIT(A)) dated 06.01.2025 wherein the Appeal filed by the Assessee against the reassessment order passed u/s.147 r.w.s. 144 of the Income Tax Act,1961 (the Act) dated 26.05.2023 passed by the National e-Assessment Centre, Delhi (the Ld. Assessing Officer) was dismissed.

3.

ITA No. 523/Bang/2025 is filed by the

The order continues below.

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