Vijay Kumar Manchanda vs. Income Tax Officer

Parties Involved

Facts Summary

The assessee, Vijay Kumar Manchanda, filed an appeal against the order of the Commissioner of Income Tax (Appeals) for the assessment year 2016-17. The assessee contended that the assessment was reopened beyond the period of three years from the end of the relevant assessment year, which is in violation of section 151 of the Income-tax Act, 1961. The assessee argued that the notice under section 148 of the Act, dated 21.07.2022, was issued without the mandatory prior approval from the Principal Chief Commissioner of Income Tax or Chief Commissioner of Income Tax. The respondent supported the impugned order and prayed for upholding the addition on merits. The Tribunal examined the orders of the lower authorities and the submissions of both parties.…

Legal Issues

• 1. Validity of reopening of assessment beyond the period of three years

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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