IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER Assessment Year: 2021-22 DCIT, Vs. M/s. Alaka Mars Pvt. Ltd., Delhi 80-81, Block C, Pocket 7, Sector 7, Rohini, New Delhi PAN: AAUCA6282D (Appellant) (Respondent)

Assessee by Sh. Amit Kumar Gupta, Adv.

Department by Sh. Manoj Kumar, Sr. DR Date of hearing 21.01.2026 Date of pronouncement 21.01.2026

ORDER

This Revenue’s appeal for assessment year 2020-21, arises against the Commissioner of Income Tax (Appeals)-29 [in short, the “CIT(A)”], Delhi’s order dated 07.08.2025 passed in case no. CIT(A), Delhi-29 10135/2020-21, involving proceedings under section 147 r.w.s. 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).

Heard both the parties. Case file perused.

2. Delay of 17 days in filing of the Revenue’s instant appeal is condoned in larger interest of justice and in light of Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC).

3. It transpires during the course of hearing that there arises the first and foremost issue of validity of the impugned reopening itself set into motion by the learned ACIT, Circle-1, Delhi vide issu