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Judgment
This assessee’s appeal for Assessment Year 2018-19 arises against the C IT(A)/NFAC, De lhi’ s DIN & order No. ITBA/NFAC/S/250/2025-26/1084022363(1) dated 23.12.2025, in proceed ings u/s 147 of the Income Tax Act, 1 961 (in short “the Act”).
Heard both the p arties at length. Case file perused.
It transpires during the course of hear ing that ther e arises the first and foremost legal issue of validity of the impugned reopening itself as the learned assessing authority had set into motion the same against the assessee regard ing the sole reason alleged purchases of Rs.1,97,61,861/- whereas his assessment fr amed on 29.02.2 024 in question ended up in disallowing/adding unexplained expenditure of Rs.24,70,232/-from undisclosed sources.
It is thus clear that the le arned assessing authority has nowhere made any addition qua the above sole reaso n of reopening. This being the clinching case, I hereby quote Ranbaxy Laboratories Ltd . vs. Union of India (2011) 336 ITR 136 (Del.) and CIT vs. Jet Airways (India) Ltd. (2011) 331 ITR 236 (Bom.) to quash the impugned reopening for the above precise reason in very terms.
This assessee’s appeal is allowed.