2025 (7) TMI 94

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....R ORDER PER YOGESH KUMAR, U.S. JM: The present appeal is filed by the Assessee against the order of the Commissioner of Income Tax (Appeal)/National Faceless Appeal Centre ('NFAC' for short) dated 15/02/2024 pertaining to Assessment Year 2012-13. 2. Brief facts of the case are that, the Assessee filed return of income of Rs. 2,82,400/-. After claiming deduction under Chapter VI-A of th....

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....19. As against the assessment order dated 17/10/2019, the Assessee preferred an Appeal before the Ld. CIT(A). The Ld. CIT(A) vide order dated 15/02/2024 dismissed the appeal filed by the Assessee, which is under challenge in the present Appeal. 3. The Ld. Counsel vehemently submitted that the reasons recorded as per Section 147 of the Act was mechanical and based on the suspicion derived from A....

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.... iv. Order of the Delhi Tribunal in the case of Space Chem Engineers Vs. ITO dated 18/03/2021 in ITA No. 1791/Del/2019. 4. Per contra, the Ld. Department's Representative submitted that the information mentioned in the reasons recorded is a credible information and A.O. has applied its mind while recording the reasons and A.O. had reason to believe that income chargeable to tax has escaped ....

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....hrough the reasons recorded by the ITO, Ward-2, Rewari, am of the view that there is no nexus between the prima facie inference arrived in the reasons recorded and information; the information was restricted to cash deposits in bank account but there was no material much less tangible, credible, cogent and relevant material to form a reason to believe that cash deposits represented income of the a....