2025 (6) TMI 1994

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....adav, Advocate For the Revenue : Sh. Manish Gupta, Sr. DR ORDER PER YOGESH KUMAR, U.S. JM: Both the above captioned Appeals are filed by the Assessee against the order of the Commissioner of Income Tax Appeal/National Faceless Appeal Centre ['Ld. CIT(A)'/NFAC for short] dated 27/03/2024 and 17/08/2023 for the Assessment Years 2011-12 and 2016-17 respectively, wherein the Ld. CIT(A) has....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... under Section 144/147 of the Act on the total income of Rs. 1,57,50,000/-. Aggrieved by the assessment order dated 14/11/2018, the Assessee preferred an Appeal before the Ld. CIT(A). The Ld. CIT(A) vide order dated 27/03/2024, dismissed the appeal filed by the Assessee. Aggrieved by the order of the Ld. CIT(A) dated 27/03/2024, the Assessee preferred the captioned Appeal in ITA No. 2546/Del/2024.....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... order of the Ld. CIT(A) requires to be quashed and consequently, the Order of penalty and the Order of CIT(A) confirming the said penalty are also liable to be set aside. 5. Per contra, the Ld. Departmental Representative relying on the orders of the Lower Authorities sought for dismissal of the Appeals. 6. We have heard both the parties and perused the material available on record. As coul....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... is clear that that the assessment order dated 14/11/2018 has been passed without serving the notice. The Assessment Order has been passed without serving the notice u/s 148 of the Act either to the registered address of the Assessee or to the address mentioned in the PAN data and the address mentioned in the Return filed by the Assessee during the relevant point of time and the Revenue has also n....