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INCOME TAX APPELLATE TRIBUNAL (AGRA BENCH)
Mahavir Singh, Vice-President, M. Balaganesh, Accountant Member
Praveen Saxena – Appellant
Versus
Income Tax Officer – Respondent
| Table of Content |
|---|
| 1. procedural history and delay condonation with cost. (Para 1 , 2) |
| 2. reopening under section 147 due to undisclosed capital gains. (Para 3 , 4) |
| 3. mechanical section 151 approval invalidates section 147 jurisdiction. (Para 5) |
| 4. dr argues minimal reasoning suffices for section 151 approval. (Para 6) |
| 5. jurisdictional allahabad hc ruling quashes invalid reopening. (Para 7) |
| 6. quashed reassessment voids section 263 revision; appeals allowed. (Para 8 , 9) |
ORDER
PER BENCH:
1. The appeal filed by the assessee in ITA No. 209/Agr/2025 is against the revision order passed by the Learned Principal Commissioner of Income Tax, Agra-1 [hereinafter referred to as the Learned PCIT] for the Assessment Year 2010-11 on 31-3-2021 under section 263 of the Income Tax Act, 1961 [hereinafter referred to as the ‘Act’] seeking to revise the assessment order passed by the Learned Income Tax Officer, Ward 4(3)(2), Etah [hereinafter referred to as the Learned AO] dated 28-03-2022. The appeal filed by the assessee in ITA No. 208/Agr/2025 is against the order passed by the Learned National Faceless Appeal Centre (NFAC) [hereinafter referred to as the Learned CITA] dated 27-9-2024 against the giving e
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