AdvertisementOrchids Diamond Tools Private Limited Vs ITO (ITAT Delhi) The assessee appealed against the order of the Commissioner of Income-tax (Appeals)-03, Gurgaon, dated 24.02.2024 for AY 2012-13, challenging the assumption of jurisdiction under Sections 147 and 143(3) of the Income-tax Act, 1961. The assessee contended that the reassessment proceedings were initiated mechanically without independent application of mind, that Explanation 2 to Section 148 did not apply, that valid approval under Section 151 had not been obtained, and that the proceedings were contrary to Section 151A of the Act.