Sanjay Kumar Vs DCIT, Circle-67(1), New Delhi

Parties Involved

Facts Summary

The instant appeal, preferred by the assessee Sanjay Kumar, is directed against the order dated 25.08.2025 passed by the National Faceless Appeal Centre (NFAC), Delhi, arising out of the order dated 29.03.2022 passed by the National Faceless Assessment Centre, Delhi in proceedings under Section 147 r.w.s. 144B of the Income Tax Act, 1961 for Assessment Year 2015-16. The matter relates to an order of approval granted by the Learned Principal Commissioner of Income Tax (PCIT) for initiation of proceedings under Section 147 of the Act. The approval document, though bearing signatures, is undated. The Departmental Representative (DR) informed the Tribunal that efforts are being made to locate the file to provide a proper response. The assessee’s Counsel relied on judgments, including the order dated 04.08.2025 passed by the Coordinate Bench in ITA No. 3688/Del/2025 Sumit Suneja v. ACIT for A.Y. 2011-12, where similar undated approvals were quashed.…

Legal Issues

• 1. Validity of undated approval granted by the PCIT for initiation of proceedings under Section 147 of the Income Tax Act, 1961.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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