SUNITA BHARDWAJ,NEW DELHI vs. ACIT CIRCLE 63(1), NEW DELHI

ITA 1435/DEL/2024Status: DisposedITAT Delhi29 August 2025AY 2012-201325 pages
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What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were invalid because the Principal Commissioner's approval was mechanical and lacked proper application of mind, as evidenced by the brief endorsement and quick turnaround time. The Tribunal relied on Supreme Court and Delhi High Court judgments regarding the proper procedure for granting approval for reassessment.

What were the facts?

The assessee, an advocate, filed her return of income. The AO initiated reassessment proceedings under Section 147 based on information received. The assessee failed to comply with notices, leading to a reassessment order with significant additions.

What were the issues?

Whether the reassessment proceedings were validly initiated due to mechanical approval by the Principal Commissioner without proper application of mind.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 151

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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 (Assessees itself)
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 dated Assessment Order under section 1 [Assessment Year 2012-13] CIT(A), NFAC, Delhi order dated 30.01.2024 28.12.2019 144 r.w.s.147 of the Income Tax Act, 19

The order continues below.

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