2025 (6) TMI 1864

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....ocate For the Revenue : Shri Narpat Singh, Sr. DR ORDER PER ANUBHAV SHARMA, JM: These appeals are preferred by the assessee against the orders dated 06.12.2024 of the Ld. Commissioner of Income-tax (Appeals), NFAC, Delhi (hereinafter referred to as the Ld. First Appellate Authority or 'the Ld. FAA', for short) in Appeals No.NFAC/2015-16/10261741 and No.NFAC/2016- 17/10261748 arising ou....

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....Y 2016-17 which are common to both the years are reproduced below:- "2. On the facts and circumstances of the case and in law, the reassessment proceedings initiated is bad in law, without jurisdiction and contrary to the provisions of law including the specific provisions of section 147 to section 151A of Income Tax Act, 1961 and therefore, the reassessment proceeding initiated along wit....

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..... The assessee company was part of the litigations. The AO has issued notice u/s 148A(b) on 27.05.2022 and on 28.07.2022 order was passed u/s 148A(d) and issued notice u/s 148 of the Act on the same date, i.e., on 28.07.2022 in AY 2016-17 and while in AY 2017-18 on 27.07.2022 order was passed u/s 148A(d) and issued notice u/s 148 of the Act on 28.07.2022. This notice dated 28.07.2022 u/s 148 of th....