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Judgment
This assessee’s appeal for assessment year 2010-11, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN & Order no. ITBA/NFAC/S/250/2025-26/1082136599(1) dated 30.10.2025, involving proceedings under section 147 of the Income-tax Act, 1961; hereinafter referred to as ‘the Act’.
Heard both the parties. Case file perused.
Coming to the first and foremost legal issue of validity of impugned reopening itself herein, it emerges from a perusal of case records that it was the learned ITO, Ward-2(1), Chandigarh who had set into motion section 148 proceedings against her on 22.03.2017 whereas she has been all along been assessed at Delhi only even going by the assessment order framed by the ITO, Ward-43(5) New Delhi. This is thus an instance of the learned ITO at Chandigarh having wrongly assumed section 148 jurisdiction in the assessee’s case in other words which vitiates the reopening under challenge as an instance of lack of jurisdictions. The same stands quashed for the very precise reason.
All other pleadings between the parties on merits are rendered academic.
This assessee’s appeal is allowed.