2026 (9) TMI 1693

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.... Act, 1961 (hereinafter referred to as 'the Act') dated 15.04.2023 for AY 2014-15 and 18.05.2023 for AY 2016-17 by the Assessing Officer, ITO, Ward-3(4), Delhi (hereinafter referred to as 'ld. AO'). ITA No. 159/ASR/2025 for AY 2014-15 2. The only addition made in the assessment is Rs. 5,75,25,315 on account of cash deposits u/s 69A of the Act which is contested before us. 3. We have heard the rival submissions and perused the material available on record. The assessee had not filed his return of income for the AY 2014-15 u/s 139 of the Act. The cash deposit made in the bank account in the sum of Rs. 5,57,68,060/- got flagged by way of information in the insight portal, basis which, assessment of the assessee was sought to be reopen....

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....ting the prior approval of the ld Principal Commissioner of Income Tax (PCIT), Srinagar, J&K, dated 08-07- 2022. This fact is mentioned in the notice u/s 148 of the Act dated 13-07-2022 enclosed in pages 196 and 197 of the paper book. When the case is sought to be reopened beyond 3 years from the end of the relevant assessment year, approval u/s 151 of the Act is to be granted by ld Principal Chief Commissioner of Income Tax (PCCIT) for the purpose of Section 148 of the Act. 5. 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 obta....