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    <title>2025 (4) TMI 1664 - ITAT DELHI</title>
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    <description>The ITAT Delhi quashed the entire reassessment proceedings after finding that the reopening of assessment was conducted without obtaining valid approval under section 151 of the Act from the competent authority as required by law. The tribunal held that the reassessment was invalid due to this procedural defect in assuming jurisdiction under section 147. Consequently, the assessee&#039;s Rule 27 Petition challenging the validity of the reassessment was allowed on this ground. Since the reassessment proceedings were quashed on jurisdictional grounds, the tribunal did not adjudicate the other legal grounds raised by the assessee or the revenue&#039;s arguments on merits, leaving these matters open for future consideration if necessary.</description>
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      <title>2025 (4) TMI 1664 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=462818</link>
      <description>The ITAT Delhi quashed the entire reassessment proceedings after finding that the reopening of assessment was conducted without obtaining valid approval under section 151 of the Act from the competent authority as required by law. The tribunal held that the reassessment was invalid due to this procedural defect in assuming jurisdiction under section 147. Consequently, the assessee&#039;s Rule 27 Petition challenging the validity of the reassessment was allowed on this ground. Since the reassessment proceedings were quashed on jurisdictional grounds, the tribunal did not adjudicate the other legal grounds raised by the assessee or the revenue&#039;s arguments on merits, leaving these matters open for future consideration if necessary.</description>
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