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2026 Supreme(Online)(ITAT) 7822

INCOME TAX APPELLATE TRIBUNAL (HYDERABAD BENCH)
Ravish Sood, Judicial Member, Madhusudan Sawdia, Accountant Member
The Prakasam District Police Welfare Association – Appellant
Versus
Income Tax Officer – Respondent


Advocates:
For the Appellants/Petitioners: Shri S. Prasad Rao, CA
For the Respondents: Shri D. Praveen, Sr. AR

Table of Content
1. assessee's grounds challenging additions and reassessment validity. (Para 7)
2. arguments on lack of proper sanction under section 151(ii). (Para 8 , 9 , 10 , 11 , 12 , 13 , 14 , 15)
3. analysis of finance act 2021 amendments and approval requirements. (Para 16 , 17 , 18 , 19 , 20)
4. quashing assessment for invalid jurisdiction assumption. (Para 21 , 22 , 23)

ORDER PER RAVISH SOOD, JM:

The present appeal filed by the assessee is directed against the order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, dated 06/06/2025, 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 05/03/2024 for the Assessment Year (AY) 2018-19. The assessee has assailed the impugned order of the CIT(A) on the following grounds of appeal:

1. Ignoring relevant judicial precedents The CIT(A) erred in distinguishing binding precedents such as GDR Finance & Leasing (P) Ltd. (Delhi HC) and G4S Secure Solutions (India) 1 (P) Ltd. (Delhi HC), WHARE additions based on incorrect INSIGHT/NMS data were quashed. The present case is on all fours

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