2025 (1) TMI 374

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....rtment : Shri Sanjay Kumar, Sr. DR ORDER PER ANUBHAV SHARMA, JM: The assessee has come in appeal against the order dated 23.02.2024 passed by the National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred as "learned First Appellate Authority" or in short "FAA") in Appeal no. CIT(A), Ghaziabad/-10155/2018-19, for the assessment year 2010-11, arising out of the order dated 26.12.2....

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....nd in law in confirming the order of the AO despite that the reasons recorded for reopening the assessment does not meet the requirements under section 147 of the Act, bad in law and are contrary to the facts (ii) That the learned CIT(A), ITD has erred both on facts and in law in confirming the reopening ignoring the fact that there is no live nexus between the reasons recorded and the be....

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...., Noida, that the assessee Sh. Rahul Tyagi, Prop. M/s Mahalaxmi Trading Co: has made bogus purchases amounting to Rs. 38,40,000/- from M/s Maa Saraswati Enterprises during the F.Y. 2009-10 relevant to AY. 2010-11. During the investigation carried out by the wing it was found that the proprietary firm M/s Maa Saraswati Enterprises does not exist on the given address of the firm. Sh. Sunil ....

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....ssment record of assessee or any other piece of document containing such information has been relied by the AO to indicate that there was any application of mind. So much so that in this sheet the AO has not even cared to look into the fact if income-tax return was already filed and without taking cognizance of return so filed the Investigating Wing report has been relied for making the reopening.....