Angad Yadav vs CIT(A)/NFAC

This assessee’s appeal for Assessment Year 2011-12 arises against the C IT(A)/NFAC, De lhi’ s DIN & order No. ITBA/NFAC/S/250/2025-26/1084175663(1) dated 29.12.2025, in proceedings u/s 147 r.w.s. 254 of the Income Tax Act, 1961 (in short “the Act”).

Heard both the p arties at length. Case file perused.

It emerges during the course o f hear ing that there arises the first and foremost issue of validity of the reopening itself for want of a valid approval by the lear ned prescribed authority u/s. 151 o f the Act. T his tribunal’s attention is invited to the approval letter (page 5 in paper book) wherein the learned prescribed authority had accepted the Assessing Officer’s reopening proposal as “I am satisfied.........”. This being the clinching factual position emanating from the reco rd, we hereby quote CIT vs. S. Goyanka Lime and Chemical Ltd . (2023) 453 ITR 242 (SC) that such a mechanical approval vitiates the entire reopening; and therefore, I accept the instant legal ground in very te rms. T his reopening is quashed therefore.

All other plead ings on merits stand rendered academic.

This assessee’s appeal is allowed.