SUNITA BHARDWAJ,NEW DELHI vs. ITO WARD 61(1), NEW DELHI

ITA 1433/DEL/2024Status: DisposedITAT Delhi29 August 2025AY 2014-201525 pages
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What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were initiated without proper application of mind by the Principal Commissioner (Pr.CIT) while granting approval. The Pr.CIT's approval was mechanical, lacking genuine satisfaction as required by law.

What were the facts?

The assessee, an advocate, filed her return of income. The Assessing Officer (AO) initiated reassessment proceedings under Section 147, issuing notices which were not complied with. The AO completed reassessment, making additions for bank deposits and notional house property income.

What were the issues?

The key issue was the validity of the reassessment proceedings initiated under Section 147, specifically whether the approval granted by the Pr.CIT for reopening the assessment was in accordance with the mandatory requirements of Section 151 of the Act.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 151,Section 68

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Income Tax Appellate Tribunal, DELHI “G” BENCH: NEW DELHI

Before: SHRI ANUBHAV SHARMA & SHRI MANISH AGARWAL

For Appellant: Ms. Sunita Bhardwaj, Advocate
For Respondent: Shri Dheeraj Kumar Jaiswal, Sr.DR
Hearing: 03.07.2025Pronounced: 29.08.2025

PER MANISH AGARWAL, AM : The captioned appeals are filed by assessee against the different orders of Ld. CIT(A) u/s 250 of the Income Tax Act, 1961 [“the Act”] arising out of different assessment orders tabulated as under:

| Sr. Nos. | ITA Nos. | CIT(A) dated | Order Assessment Order dated | Assessment Order under section 1 | ITA No.1435/Del/2024 [Assessment Year 2012-13] CIT(A), NFAC, Delhi order dated 30.01.2024 28.12.2

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