TaxTMI 
TaxTMI 
2025 (6) TMI 52
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....d against the order passed by the Ld. CIT(A) NFAC, Delhi, dated 09.10.2024 arising out of the order dated 04.03.2022 passed by the NWR-W-(51)(1) Bharuch under Section 147 r.w.s 144 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') for Assessment Year 2013-14 whereby and whereunder the addition to the tune of Rs. 10,73,978/- made by the Ld. AO applying the test of human probability....
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.... assessee duly submitted the loan confirmation of the loan creditors as directed by the Ld. AO. She has submitted her return of income in SUGAM-4 declaring total turnover for Rs. 25,50,000/- and calculated presumptive income under Section 44AD to the tune of Rs. 2,04,000/-. Further she disclosed income from other sources of Rs. 1,45,220/- and claimed deduction under Chapter VIA. Consequently total....
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....her that the assessee categorically requested for a copy of the reason recorded by the Ld. AO for reopening of assessment along with the copy of the standard format wherein the approval of the higher authorities was obtained and further that the copy of the statement/material relied upon by the Ld. AO for forming a belief that the income had escaped assessment in order to enable the assessee to ra....
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....y of the copy of reason so recorded by the Ld.AO for reopening of assessment under Section 148 of the Act in spite of specific request made by the AO has not been able to be controverted by the Ld. DR. Under this facts and circumstances of the matter the judgment relied upon by the Ld. AR was duly considered and it is found that where the assessee was not given the copy of reason of reopening for ....