ITA 2874/DEL/2026

Parties Involved

Facts Summary

The appeal by the assessee, Shri Davendra Singh, is directed against the order of the Commissioner of Income Tax (Appeals)/Addl./JCIT(A), Jodhpur, dated 12.01.2026, for Assessment Year 2012-13. The assessee has raised an additional ground of appeal challenging the validity of the approval under section 151 of the Income-tax Act, 1961. The assessee argues that the approval for initiating proceedings under section 148 was granted in a mechanical and perfunctory manner without proper application of mind. The Departmental Representative defended the impugned order and the approval granted by the PCIT. The assessee's contention is that the approval for initiating proceedings under section 148 is mechanical and unsustainable.…

Legal Issues

• 1. Whether the approval for initiating proceedings under section 148 of the Act is mechanical and unsustainable.

Judgment Outcome

Decided in favour of Assessee.

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