2025 (6) TMI 720

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....s an appeal by the assessee against order dated 17.03.2025, passed by National Faceless Appeal Centre ('NFAC' for short), Delhi for the assessment year (A.Y.) 2006-07. 2. In ground nos. 1 & 2, the assessee has challenged the validity of reopening of assessment u/s. 147 of the Act. 3. Briefly stated, the assessee is a resident individual. For the assessment year under dispute, the assessee had fi....

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....ections questioning the validity of reopening of assessment on the ground of lack of proper approval by the competent authority. The objections filed by the assessee were rejected by the AO. Thereafter, the A.O. proceeded to complete the assessment u/s. 143(3) / 147 of the Act vide order dated 30.03.2015, adding back an amount of Rs. 1,89,49,053/-, representing alleged unexplained credits in HSBC ....

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....ner of Income Tax/Commissioner of Income Tax. He submitted, in the facts of assessee's case, no approval of the competent authority in terms with section 151(1) of the Act was taken prior to issuance of notice u/s. 148 of the Act. Thus, it was contended that the entire proceeding relating to reopening of assessment is vitiated, hence, invalid. In support of such contention, ld. Counsel appearing f....

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....ions contained u/s. 151(1) of the Act, we find, in a case where original assessment has been completed u/s. 143(3)/147 of the Act and the proceedings u/s. 147 of the Act is initiated after expiry of four years from the end of the relevant assessment year, as per the proviso to section 151(1) of the Act, as it stood prior to amendment and is applicable to the assessment year under dispute, the comp....