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INCOME TAX APPELLATE TRIBUNAL (HYDERABAD BENCH)
Ravish Sood, Judicial Member, Madhusudan Sawdia, Accountant Member
Vindhya Pharma (India) Private Limited – Appellant
Versus
DCIT Circle-8(1) Hyderabad – Respondent
| Table of Content |
|---|
| 1. ao reopens based on dggi info on bogus purchases. (Para 2 , 3 , 4 , 5 , 6) |
| 2. assessee argues lack of specified authority approval. (Para 7 , 8 , 9) |
| 3. post-2021 s.151 requires pccit approval after 3 years. (Para 10 , 11) |
| 4. cbdt instruction mandates specified authority approval. (Para 12) |
| 5. 2023 proviso to s.151 not retrospective. (Para 13) |
| 6. telangana hc confirms pccit approval needed for ay 2018-19. (Para 14 , 15) |
| 7. invalid approval quashes s.147 assessment. (Para 16) |
| 8. appeal allowed; other issues left open. (Para 17 , 18) |
ORDER
PER. RAVISH SOOD, J.M:
The present appeal filed by the assessee company is directed against the order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, dated 16/09/2025, which in turn arises from the order passed by the Assessing Officer (for short, “AO”) under section 147 r.w.s 144B of the Income Tax Act, 1961 (for short, “the Act”), dated 18/03/2024 for the Assessment Year (AY) 2018-19. The assessee company has assailed the impugned order of the CIT(A) on the following grounds of appeal:
1. The order passed by the Ld. CIT(A) u/s 250 of the Act dated 16.09.2025 is erroneous both on facts and in law
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