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Judgment
O R D E R
PER MADHUMITA ROY, J. M.:
The instant appeal filed by the Assessee is directed against the order dated 29.12.2025 passed by the Ld. Commissioner of Income-tax (Appeals)/National Faceless Appeal Centre, Delhi [hereinafter referred to as the Ld. CIT(A)/NFAC] under Section 250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) arising out of the Assessment Order dated 10.05.2023 passed by the Assessment Unit, Income-tax Department (hereinafter referred to as ‘the ld. AO’) under Section 147 read with Section 144B of the Income Tax Act, 1961 ('Act' for shot) for Assessment Year 2016-17.
Having regard to the fact of the approval under Section 148 of the Act dated 28.05.2021 appearing at page 1 of PB which was issued beyond three years from the end of the relevant to A.Y, since without approval by the PCCIT but only from the PCIT, the ratio laid down in the case of Union of India vs. Rajiv Bansal reported in (2024) 469 ITR 46 (S.C)is found to be squarely covered. The notice under Section 148 notice itself found to be invalid and assumption of jurisdiction, therefore, bad in law and the reassessment is quashed.
In the result, appeal filed by the Assessee is allowed.
Order pronounced in the open court on 27 /07/2026.