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2025 Supreme(Online)(ITAT) 3994

INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
SHRI SANDEEP GOSAIN, JM, SHRI GIRISH AGRAWAL, AM
ABHISHEK SUNILKUMAR GOYAL MUMBAI – Appellant
Versus
INCOME TAX OFFICER WARD 22(1)(1) MUMBAI – Respondent


Advocates:
For the Appellants/Petitioners: Shri Dharan Gandhi
For the Respondents: Shri Aditya M. Rai (Sr. DR)

Table of Content
1. assessment reopening requires statutory approvals. (Para 1 , 2 , 3 , 4)
2. jurisdiction issues arise from non-compliance with approval requirements. (Para 5 , 6 , 7)

आदेश/ORDER

PER SANDEEP GOSAIN, JM:

The present appeal has been filed by the assessee challenging the impugned order dt. 17.04.2025 passed under section 250 of the Income Tax Act, 1961 (‘the Act’), by the National Faceless Appeal Centre (NFAC) / CIT(A) for the assessment year 2016-17.

2. At the very outset, Ld. AR appeared on behalf of the assessee pressed ground No. 2, which is legal in question and relates to challenging the order of Ld. CIT(A) in upholding the approval sought by the AO while initiating proceedings of reopening. Therefore we have decided to adjudicate this ground firstly as it goes to the roots of the case.

3. We have heard the counsels for both the parties, perused the material placed on record, judgments cited before us and the orders passed by the revenue authorities. From the records, we noticed that the year under consideration is A.Y 2016-17 and the proceedings u/s 148A(d) of the Act in consequence to Hon’ble Supreme Court’s order 04.05.2022 were initiated and consequently the ord

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