MURARI LAL THROUGH LEGAL HEIR SAVITRI DEVI,FARIDABAD vs. INCOME TAX OFFICER, FARIDABAD
Before: SHRI SATBEER SINGH GODARA & SHRI MANISH AGARWALAssessment Year: 2014-15 Sh. Murari Lal through legal heir Savitri Devi, 581/1, Near Syndicate Bank, Village Tilpat, Faridabad Vs. Income Tax Officer, Ward-1(5), Faridabad, Haryana PAN: AHTPL3912E (Appellant)
PER SATBEER SINGH GODARA, JM
This assessee’s appeal for assessment year 2014-15, 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/250/2024-25/1071249423(1), dated
16.12.2024 involving proceedings under section 147 r.w.s. 144 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file perused.
Assessee by Sh. M.K. Gupta, CA
Department by Sh. Manish Gupta, Sr. DR
Date of hearing
24.12.2025
Date of pronouncement
24.12.2025
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Delay of 111 days in filing of the assessee’s instant appeal is condoned in larger interest of justice and in light of Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC). 3. It emerges during the course of hearing that there arises the first and foremost issue of the validity of the impugned reopening 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 “yes I am satisfied………” than having applied its independent mind thereupon. 4. We thus are 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.
5. This assessee’s appeal is allowed.
Order pronounced in the open court on 24th December, 2025 (MANISH AGARWAL)
JUDICIAL MEMBER
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Dated: 30th December, 2025. RK/-