2025 (6) TMI 1075

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....hri Saksham Agrwal, CA For The Revenue : Shri Surender Pal, CIT DR ORDER PER M. BALAGANESH, A. M.: 1. The appeal in ITA No.384/Del/2023 for AY 2012-13, arises out of the order of the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as "ld. NFAC‟, in short] in Appeal No. ITBA/NFAC/S/250/2022-23/1049737880(1) dated 14.02.2023 against the order of assessment pa....

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....2-13 was filed by the assessee, the ld AO formed a belief that income of the assessee had escaped assessment and issued notice u/s 148 of the Act on 28.03.2019. The assessee filed its return of income on 20.04.2019 declaring total income of Rs. 1,22,448/- in ITR-6. The reassessment was completed u/s 143(3) read with Section 147 of the Act on 27.12.2019 determining the total income of the assessee ....

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.... which are all reproduced in page 21 to 33 of the First Appellate order. The NFAC merely addressed the validity of assumption of jurisdiction u/s 147 of the Act on general terms without addressing the specific objections raised by the assessee in its written submission and upheld the action of the ld AO in assuming jurisdiction u/s 147 of the Act. Thereafter, the ld NFAC upheld the addition made b....

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.... entire appeal to the file of the ld NFAC for de novo adjudication in accordance with law. The assessee is at liberty to raise additional grounds, if any, and additional evidences, if any, in support of its contentions. The ld NFAC is directed to dispose of the appeal after duly considering all the contentions of the assessee by passing a speaking order, uninfluenced by orders passed by its predec....