TaxTMI 
TaxTMI 
2025 (2) TMI 1995
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.... Shri Sahil Kumar Bansal, Sr. DR ORDER PER ANUBHAV SHARMA: JUDICIAL MEMBER: This appeal is directed by the assessee against the order dated 28.03.2024 passed by the Learned Commissioner of Income- Tax(Appeals)/National Faceless Assessment Centre (NFAC), Delhi (hereinafter referred to as "CIT(Appeals)" pertaining to assessment year 2012-13 and arises out of the assessment order dated 29.11....
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....ecording reasons and for obtaining approval at page nos. 31-32 of the paper books and the same shows that for initiating proceedings under Sections 147/148 of the Act and for obtaining approval under Section 151 of the Act, the Assessing Officer, has sought the sanction and the same has been first granted by Addl./Joint Commissioner of Income Tax followed by the endorsement of the sanction by the ....
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....opinion, is against the settled principles of natural justice as reopening of an assessment is an extraordinary power available to the id AO and it should not be done in a cavalier manner. That is why the legislature in its wisdom had put lot of restrictions by imposing conditions for seeking approval and sanction from a superior officer in terms of section 151 of the Act. Hence the said approval ....
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....ct to be done in a particular manner, more particularly acts conferring jurisdiction like the present one, then, such act has to be done in that manner alone and the same cannot be compromised in any manner whatsoever. On perusal of the standard proforma for seeking approval in terms of section 151 of the Act, the legislature in its wisdom had prescribed such proforma, clearly demarcating and defi....