2026 (7) TMI 789

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....Jain, Chartered Accountant For the Respondent : Sh. Manoj Kumar, Sr. DR ORDER PER VIKAS AWASTHY, JUDICIAL MEMBER: This appeal by the assessee is directed against the order of Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [in short 'the CIT(A)'] dated 16.10.2025, for Assessment Year 2019-20. 2. Shri Mani Bhadra Jain, appearing on behalf of the assessee ....

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....u/s. 149(1)(b) of the Act, i.e., more than three years but not more than ten years". Even if it is accepted that notice u/s. 148A(b) of the Act is issued within three years and approval is by the Competent Authority under the Act, the manner in which PCIT has sanctioned approval is itself testimony to the fact that the same has been accorded in mechanical manner without application of mind by the ....

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....ng of Assessment Year 2019-20, notice u/s. 148 of the Act was issued to the assessee on 12.04.2023. The notice issued u/s. 148 of the Act is visibly issued beyond the period of three years from the end of relevant assessment year. As is evident from the copy of approval dated 12.04.2023 available at pages 32 and 33 of the paper book, the approval u/s. 151 of the Act for reopening the assessment wa....