ITA 3060/DEL/2026

Parties Involved

Facts Summary

The assessee, SIRVINDER SINGH, filed an appeal against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre's order no. ITBA/NFAC/S/250/2025-26/1080087049(1), dated 28.08.2025, involving proceedings under section 147 r.w.s. 144 r.w.s. 144B of the Income-tax Act, 1961. The assessee argued that the reopening of the case was invalid as it was initiated without the proper approval under section 151(ii) of the Act. The Revenue argued that the approval was correctly granted by the PCIT. The Tribunal relied on the Bombay High Court's decision in Vodafone Idea Limited vs Deputy Commissioner of Income Tax, which held that such proceedings should be initiated only after obtaining the PCCIT's approval.…

Legal Issues

• 1. Validity of the impugned reopening of the case

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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