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Judgment
ORDER
This assessee’s appeal for Assessment Year 2020-21 arises against the CIT(A)-30, New De lhi’s DIN & order No. ITBA/APL/M/250/2025-26/1083460663(1) dated 09.12.2025 , in proceedings u/ s 147 r.w.s. 144 of the Income Tax Act, 1961 (in shor t “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 of the Act. The trib unal’s attention is invited to the approval dated 22.03.2024 (page 3 in paper book) wherein the learned prescr ibed author ity had accepted the Assessing Officer’s reopening proposal as “approved”. 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.