VIKAS CHANDRA HUF,ALIGARH vs. ITO WARD-4(1)(1), ALIGARH

ITA 450/AGR/2025Status: DisposedITAT Agra21 January 2026AY 2020-21Bench: SHRI M. BALAGANESH (Accountant Member)11 pages
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What did the Tribunal hold?

The Tribunal held that the approval granted by the PCIT for reopening the assessment was mechanical and lacked application of mind, citing several High Court decisions. Consequently, the reassessment proceedings were quashed.

What were the facts?

The Assessing Officer (AO) reopened the assessment of Vikas Chandra HUF under Section 147 of the Income-tax Act, 1961, based on information from the investigation wing. The approval for reopening was granted by the Principal Commissioner of Income Tax (PCIT) under Section 151.

What were the issues?

The key issue was whether the approval granted by the competent authority for reopening the assessment under Section 151 was valid or if it was granted mechanically without due application of mind.

Which sections of the Income-tax Act were involved?

Section 147,Section 143(3),Section 144B,Section 148,Section 151

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Income Tax Appellate Tribunal, AGRA BENCH “SMC”: AGRA

For Appellant: Shri Pankaj Garg, Adv
For Respondent: Shri Anil Kumar, Sr. DR
Hearing: 21/01/2026Pronounced: 21/01/2026
1.

The appeal in ITA No. 450/AGR/2025 for AY 2020-21, arises out of the order of the National Faceless Appeal Centre, Delhi [hereinafter referred to as „ld. CIT(A)‟, in short] dated 04.08.2025 against the order of assessment passed u/s 147 r.w.s. 143(3) r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as „the Act‟) dated 06.03.2025 by the Assessing Officer, ITO, Ward-4(1)(1), Aligarh (hereinafter referred to as „ld. AO‟).

2.

Though the assessee has raised several grounds challenging the validity of assumption of juri iction u/s 147 of the Act together with merits, I find that the assessee had also raised additional ground no. 3 stating that the approval granted u/s 151 of the Act by the competent authority for reopening the assessment is mechanical in nature. Since this additional ground goe

The order continues below.

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