2025 (7) TMI 1307

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....R, AM: This is an appeal preferred by the assessee against the order of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the "Ld. CIT(A)"] dated 19.11.2024 for the AY 2014-15. 02. At the time of hearing, the assessee pressed the ground no.4, which is against the order of ld. CIT (A) upholding the reopening of assessment u/s 148 of the Act without any tangible material w....

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.... evidenced that no such amount has ever been received by the assessee. The ld. AO during the re-assessment proceeding also reiterated the same facts despite the assessee denying the said claim of the AO of having received such amount from Shri Swapan Das. Finally, the amount was added to the income of the assessee in the assessment framed u/s 143(3)/147 of the Act. 04. In the appellate proceedi....