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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
SHRI S. RIFAUR RAHMAN, ACM, SHRI YOGESH KUMAR U.S., JM
Rajbir Singh – Appellant
Versus
ACIT – Respondent
| Table of Content |
|---|
| 1. approval under section 151 must align with statutory requirements. (Para 1 , 2 , 3) |
| 2. arguments regarding the validity of the approval process. (Para 4 , 5) |
| 3. reassessment notices lack legitimacy without proper authority approval. (Para 6) |
ORDER
PER YOGESH KUMAR, U.S. JM:
The present appeal is filed by the Assessee against the order of the Commissioner of Income Tax (Appeals)-27, Delhi [‘Ld. CIT(A) ’ for short] dated 27/02/2025 pertaining to Assessment Year 2013-14.
2. There is a delay of 09 days in filing the present appeal and the Assessee filed an application for condonation of delay. For the reasons stated in the application for condonation of delay filed by the Assessee, the delay of 09 days in filing the present Appeal is hereby condoned.
3. The Ld. Counsel for the Assessee submitted that the approval under Section 151 of the Income Tax Act, 1961 ('Act' for short) has been obtained from Pr. Commissioner of Income Tax, Delhi-1, and should have been obtained from PCIT. The Ld. Counsel relied on the order of the Co- ordinate Bench of the Tribunal in the case of Amrit Pal Singh Vs. ACIT in ITA No. 2794/Del/2025 dated 21/07/2025, wherein the Co-ordinate Bench of the
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