2025 (11) TMI 1769

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..... Astha Sharma, Adv. For the Revenue : Shri Om Prakash, Sr. DR ORDER PER M. BALAGANESH, A. M.: 1. The appeal in ITA No. 2908/Del/2025 for AY 2017-18, arise out of the order of the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as "ld. NFAC", in short] in Appeal No. ITBA/NFAC/S/250/2024-25/1074408001(1) dated 12.03.2025 against the order of assessment passed u/s ....

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....51 of the Act from the Learned PCIT which fact is quite evident from the order passed under section 148 of the Act dated 21-7-2022. Since the reopening in the instant case has been made beyond 3 years from the end of the relevant assessment year, the specified sanctioning authority for the purposes of section 148 of the Act is Learned PCCIT. Since the approval in the instant case has been obtained....

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....ntoor, learned counsel, had submitted that the said sanction accorded by the Principal Commissioner of Income Tax ["PCIT"] would not sustain. 4. We note that while dealing with the said question, we had in Abhinav Jindal H.U.F. v. Commissioner of Income Tax and Ors [2024 SCC OnLine Del 6585] duly enunciated the legal position which would obtain. We had ultimately in Abhinav Jindal held th....