ACIT, NEW DELHI vs. JAKSON LIMITED, DELHI

ITA 5010/DEL/2024Status: DisposedITAT Delhi23 December 2025AY 2016-17Bench: MS. MADHUMITA ROY (Judicial Member), MRS. RENU JAUHRI (Accountant Member)10 pages
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What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were invalid because the approval for issuing the notice under Section 148 was not obtained from the specified authority (PCCIT/CCIT) as required by Section 151(ii) of the Act, following the Supreme Court's decision in Rajeev Bansal.

What were the facts?

The assessee filed returns for AY 2016-17, which were revised. The case was reopened based on information regarding bogus purchases, leading to a reassessment. The assessee appealed the reassessment order, and both the assessee and revenue filed appeals against the CIT(A)'s order.

What were the issues?

The primary issue was the validity of the reassessment proceedings due to improper approval obtained under Section 151 for issuing the notice under Section 148.

Which sections of the Income-tax Act were involved?

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

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Cases cited in this judgment(2)Show list

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Income Tax Appellate Tribunal, DELHI BENCH ‘C’, NEW DELHI

Before: MS. MADHUMITA ROY & MRS. RENU JAUHRI

For Appellant: Shri S.S. Nagar, CA
For Respondent: Shri Chandra Bhanu Mandal, SR. DR
Hearing: 23.12.2025Pronounced: 23.12.2025

Heard together (3 matters)

ITA No. 5010/DEL/2024
ITA No. 4987/DEL/2024
ITA No. 5014/DEL/2024

Read from the judgment's own cause title. This page is filed under one of them.

PER BENCH :

1.

The above captioned appeals are filed by the Revenue as well as assessee against the order u/s 250 of The Income Tax Act, 1961

ITA No. 5014, 5010, 4987/DEL/2024 (hereinafter referred to as, “Act”), order dated 28.10.2024, passed by CIT(A), Delhi.

2.

In the departmental appeals No. ITA No. 5010/DEL/2024 & ITA No. 4987/DEL/2024, the grounds of appeal are identical. Hence, Appel No. 4987

The order continues below.

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