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Judgment
This assessee’s appeal for assessment year 2017-18, arises against the National Faceless Appeal Centre (NFAC), Delhi [in short, the “CIT(A)] dated 12.09.2025 involving proceedings under section 143(3)(/147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file perused.
Delay of 86 days in filing of the assessee’s instant appeal is condoned in larger interest of justice and in light of Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC).
It transpires during the course of hearing that the heard assessing authority had initiated the impugned reopening in assessee’s case on 30.07.2022 i.e. beyond the period of 3 years but within 6 years from the end of the relevant assessment year, for the purpose of assessing his cash deposits amounting to Rs. 16,74,500/- which is admittedly less than the prescribed limit of Rs. 50 lakhs u/s 149(1)(b) of the Act. This being the clinching factual position. I find no merit in the Revenue’s vehement contention supporting the impugned reopening which is hereby quashed for this precise reason in very terms.
All other pleadings between the parties on merits stands rendered academic.
This assessee’s appeal is allowed.