SOCIETY FOR ADVANCEMENT IN EDUCATION,MUSSOORIE vs. ITO EXEMPTION WORD DEHRADUN, DEHRADUN

ITA 219/DDN/2025Status: DisposedITAT Dehradun18 February 2026AY 2010-11Bench: YOGESH KUMAR U.S. (Judicial Member), SHRI SANJAY AWASTHI (Accountant Member)11 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the sanction for reopening the assessment was granted in a mechanical manner, evidenced by rubber-stamped approvals without independent application of mind. Consequently, the notices issued under Section 148 and the consequent reassessment orders were quashed.

What were the facts?

The assessee's appeals were filed against assessment orders passed under Section 143(3)/147 of the Income Tax Act. The primary contention was that the notice issued under Section 148 was based on a mechanical sanction under Section 151, rendering the assessment invalid.

What were the issues?

Whether the sanction for issuing notice under Section 148 was validly granted, considering the manner in which it was recorded by the competent authority.

Which sections of the Income-tax Act were involved?

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

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Cases cited in this judgment(5)Show list

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Income Tax Appellate Tribunal, DEHRADUN BENCH, DEHRADUN

Before: YOGESH KUMAR U.S. & SHRI SANJAY AWASTHI

Hearing: 09/02/2026Pronounced: 18/02/2026

PER YOGESH KUMAR, U.S. JM: The captioned Appeals are filed by the Assessee against the orders

of Ld. Commissioner of Income Tax (Appeals)/National Faceless Appeal

Centre (‘Ld. CIT(A)/NFAC’ for short), New Delhi dated 09/09/2025 for the Assessment Years 2009-10 & 2010-11 and the order dated

04/09/2025 for A.Y 2011-12 respectively.

2.

Brief facts of the case are that, assessment orders came to be passed on 26/12/2016 for A.Y 2009-10 to 2011-12 under Section 143(3)/147 of the Income Tax Act, 1961 ('Act' for short) against the Assessee by making certain additions

The order continues below.

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