2025 (3) TMI 1464

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Sr. DR ORDER MANOJ KUMAR AGGARWAL (ACCOUNTANT MEMBER) 1. Aforesaid twin appeals by assessee for Assessment Year (AY) 2012-13 arises out of separate orders of first appeal authority. ITA No.537/Agr/2024 is quantum appeal that arises against the order of Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [CIT(A)] dated 06-09-2024 in the matter of an assessment....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nfirmed in first appeal for want of condonation of delay and for want of any representation from the assessee. Aggrieved, the assessee is in further appeal before us. 3. The Ld. AR took us through the reasons recorded for reopening the case of the assessee which is placed on Page No.8 of the paper-book. In para-4 of the reasons, Ld. AO alleged that the assessee did not file any return of income a....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....that the factor of non-filing of return of income has overbearingly weighed with the AO for arriving at satisfaction about the failure on the part of the assessee about escapement of income. Therefore, the assessment stood vitiated. Similar is the analogy in the decision of Lucknow Tribunal in the case of Ritika Gupta (2022; (8) TMI 796) which referred to the decision of Hon'ble High Court of Alla....