GOPAL SNACKS PVT LTD ,RAJKOT vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAJKOT

ITA 499/RJT/2025Status: DisposedITAT Rajkot08 December 2025AY 2020-21Bench: DR. ARJUN LAL SAINI (Accountant Member), SHRI DINESH MOHAN SINHA (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the approval for initiating reassessment proceedings under Section 151 of the Income Tax Act was invalid due to the absence of a signature from the concerned authority. Consequently, the reassessment order framed by the AO was quashed.

What were the facts?

The assessee filed its return of income, which was processed by the CPC. Subsequently, the case was selected for scrutiny, and the Assessing Officer (AO) completed the assessment without making any additions, adopting the income as processed by the CPC. The assessee appealed to the CIT(A), arguing that the AO was not justified in adopting the processed income. The CIT(A) dismissed the appeal, stating that no adverse action was taken in the assessment order and the grievance arose from the initial processing.

What were the issues?

Whether the reassessment proceedings were validly initiated without a properly signed approval under Section 151 of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 151,Section 143(1),Section 143(3)

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Cases cited in this judgment(2)Show list

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Income Tax Appellate Tribunal, RAJKOT BENCH, RAJKOT

Before: DR. ARJUN LAL SAINI & SHRI DINESH MOHAN SINHA

Hearing: 19/11/2025Pronounced: 08/12/2025

Per, Dr. Arjun Lal Saini, Accountant Member: Captioned two appeals filed by the same assessee, pertaining to assessment years ( A.Ys.) 2015-16 & 2020-21, are directed against the separate orders passed under section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by National Faceless Appeal Centre (NFAC), Delhi / Commissioner of Income-tax

The order continues below.

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