2025 (8) TMI 30

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....Y T. VARKEY, JM: This is an appeal preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeals)/NFAC, (hereinafter referred to as "the Ld.CIT(A)"), Delhi, dated 13.12.2024 for the Assessment Year (hereinafter referred to as "AY") 2017-18. 2. At the outset, the Ld.AR of the assessee submitted that the AO had passed an ex parte order, though he had mentioned in ....

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....here is non-application of mind on the part of Ld CIT(A) while passing the impugned order, which vitiates the action of Ld CIT(A). Further, according to him, even the AO has not given proper opportunity to assessee to substantiate her claim regarding addition of SBNs of Rs. 38,50,000/- as well as Rs. 15,00,000/- [Total Rs. 53,50,000/-] given an opportunity before AO, the assessee undertakes to fil....

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.... erroneous and based on "mistake of fact". In this regard, no order of Ld CIT(A) disposing of the appeal as observed by Ld CIT(A) is placed on records. Therefore, the impugned action of Ld CIT(A) can't be countenanced. Be that as it may, since assessee has asserted that she didn't file any duplicate appeal before the Ld.CIT(A), the reason given by the Ld.CIT(A) can't be sustained and therefore, it....