AI Structured Summary
Not yet generated for this judgment
Judgment
This assessee’s appeal for Assessment Year 2017-18, arises against the C IT(A)/NFAC, Delhi’s DIN & order No. ITBA/NFAC/S/250/2025-26/1082738700(1), date d 18.11.2025 in proceed ings u/s 147 of the Income Tax Act, 1961 (in short “the Act”).
Heard both the p arties. Case file perused.
It is evident at the outset that there arises the first and foremost legal issue of valid ity of the impugned reopening between the parties. There is hardly any disp ute that the assessment herein is for AY 2017-18. And that the learned lower authorities had initiated the impugned reopening against the assessee vide Section 148 notice issued on 8 March, 2024. There is further no quarrel that all what is assessed/sought to be assesse d herein is income in the assessee’s hands representing interest as its alleged unexplained expenditure of Rs.11,04,658/- which is in any case less than the statutory pecuniary limit of Rs.50 lakhs going by Section 149(1)(b) of the Act.
This be ing the clinching factual positio n, the tribunal hereby finds no merit in the impugned reopening which is hereby quashed in very terms.
All other remaining pleadings between the parties on merits stand rendered academic.
The assessee’s appeal is allowed.