2025 (3) TMI 1274

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....CIT, Sr. DR ORDER PER SHRI RAJESH KUMAR, AM The appeal filed by the assessee is against the order of Ld. CIT(A), National Faceless Appeal Centre (NFAC), Delhi dated 08.05.2023 for AY 2010-11 arising out of assessment order passed u/s. 143(3)/147 of the Income Tax Act, 1961 (hereinafter referred to as the "Act") by ITO, Ward-1(3), Kolkata dated 11.12.2017. 2. At the outset, we note that....

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....sessee's counsel therefore requested that the delay in filing the appeal may be condoned and it may be adjudicated. The ld. DR on the other hand opposed the condonation of delay that the notices and appellate order was sent on the email id of the assessee nonetheless it was old one. Therefore, the appeal may not be admitted. After hearing the rival contentions and perusing the condonation petition....

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....3.2017. The assessee complied with the said notice by filing the return of income on 16.08.2017 and also requested for giving the reasons recorded u/s. 148(2). Thereafter, the assessee furnished all the details and evidences as called for by the Assessing Officer in the questionnaire issued from time to time. Thereafter, the Assessing Officer in a very cryptic manner noted that the investments rec....

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....dited financial statements for FYs 2010-11 and 2022- 23 and also the assessment order u/s. 147/143(3) for AY 2010-11 in the case of investor company. All these evidences are available in the paper book from pages 18 to 50. We note that both the authorities below have not examined these evidences and without examining and by relying on the general modus operandi of accommodation entry operators, tr....