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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
Challa Nagendra Prasad, Judicial Member, Amitabh Shukla, Accountant Member
Colvin Care Pvt. Ltd. – Appellant
Versus
DCIT, Circle-4(2) – Respondent
| Table of Content |
|---|
| 1. factual matrix of reassessment notices and procedural history. (Para 2 , 3 , 4) |
| 2. challenge to pr. cit approval validity under s.151(ii). (Para 5 , 6) |
| 3. analysis of precedents mandating pr. ccit sanction post-3 years. (Para 7 , 8 , 9 , 10 , 11) |
| 4. notice u/s 148 quashed for lack of proper approval; appeal allowed. (Para 12 , 13 , 14) |
ORDER
PER AMITABH SHUKLA, AM,
This appeal by the assessee is directed against the order of National Faceless Appeal Centre/Ld. Commissioner of Income Tax(Appeals), New Delhi, [hereinafter referred to as ‘ld. CIT(A)] dated 13.08.2025 arising out of assessment order dated 30.05.2023 passed under section 147 of the Income Tax Act, 1961, for the Assessment Year 2016-17. The word ‘Act’ herein this order would mean Income Tax Act, 1961.
2. The assessee has raised following grounds of appeal:-
1. The assessment order passed in the present case is based on personal whims and fancies without ascertaining the facts and circumstances of the case. Hence liable to be quashed.
2. That the approval given by the Ld. Pr. Commissioner of Income Tax, Rohtak to the order passed u/s 148A(d) as well as issue of notice u/s 148 is out of jurisdiction, which makes
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