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"7. After considering the rival submissions, we are of the view that the issue is
covered by the Order of ITAT, Delhi G-Bench, Delhi in the case of VRC
Township Pvt. Ltd., Delhi (supra) in which reopening of the assessment in
identical circumstances was held to be bad in law and sanction accorded by the
Sanctioning Authority was also found invalid, therefore, reopening of the
assessment was quashed. In the present case, the Learned Counsel for the
Assessee has pointed-out that assessee has raised this issue before the
Ld. CIT(A), but, he has rejected the submissions of the assessee holding
that Section 147(b) as mentioned in the reason and Format is a
typographical human error which is curable under section 292B of the I.T.
Act, 1961. This issue is also considered in the Order of VRC Township Pvt.
Ltd., (supra) following the decision of Hon'ble Bombay High Court in the
case of Kalpana Shantilal Haria vs. ACIT [2017] 100 CCH 165 (Bom.).
Following the same reasons for decision, we set aside the Orders of the
authorities below and quash the reopening of the assessment in both the
assessment years under appeals. All additions stand deleted. Accordingly,
appeals of the Assessee are allowed."