Reshma Harbakhsh Singh through Legal Heir Vikaramaditya Singh VS DCIT

Parties Involved

Facts Summary

The assessee, Ms. Reshma Harbakhsh Singh, did not file her return for the Assessment Year 2018-19. Based on information regarding the sale of immovable property, a notice under Section 148 was issued to her on 04.04.2022 after obtaining prior approval from the PCIT, Delhi-10. The assessment was completed on 19.02.2024 under Sections 147, 144, and 144B of the Income Tax Act at an income of Rs. 1,81,40,049/-. The assessee's appeal was dismissed by the Commissioner of Income Tax (Appeals)/ National Faceless Appeal Centre, New Delhi on 31.08.2025. The legal heir of the assessee raised several grounds of appeal, challenging the validity of the assessment order, the notice issued under Section 148, and the sanction obtained under Section 151, among other things.…

Legal Issues

• 1. Validity of the assessment order passed under Section 147 read with Section 144 of the Act
• 2. Validity of the order passed under Section 148A(d) of the Act
• 3. Validity of the notice issued under Section 148 of the Act
• 4. Validity of the approval granted under Section 151 of the Act
• 5. Validity of the notice issued under Section 148A(b) of the Act
• 6. Erroneous addition of Rs. 1,80,00,000/- by the Assessing Officer

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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