2025 (8) TMI 526

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.... For The Assessee : Shri Hitesh M. Shah, C.A. For The Revenue : Shri Pushkaraj Bhangepatil, Sr. D/R ORDER PER NARENDRA KUMAR BILLAIYA, AM: This appeal by the assessee is preferred against the order dated 10/09/2024 by NFAC, Delhi [hereinafter 'ld. CIT(A)'], pertaining to AY 2016-17. 2. The grievance of the assessee reads as under:- "1) That on the facts and in the circums....

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....he appellant and in law Ld. NFAC has erred in upholding the assessment order u/s. 147 r.w.s. 144B dated 30.05.2023 passed by the Assessing Officer even when it was barred by limitation as per Section 149 of the Act. 4) Without prejudice to the above grounds, that on the facts and in the circumstances of the case of the appellant and in law Ld. NFAC has erred in upholding the addition made....

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....l for the assessee stated that he is not pressing Ground Nos. 1, 2 & 3. Therefore, the same are dismissed as not pressed. 4. The only ground which needs to be adjudicated is in respect of addition of Rs. 2,14,50,000/- made by the AO u/s 69A of the Act. 5. Briefly stated, the facts of the case are that as per the information available with the Department, the AO came to know that the assessee....

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.... perusal of the aforementioned chart shows that the investment of Rs. 1,10,50,000/- has been made in FY 2013-14 and 2014-15 relevant to 2014-15 and 2015-16. Therefore, there is no question of making the addition in the Assessment Year under consideration i.e., AY 2016-17. Therefore, the AO is outrightly directed to delete the addition of Rs. 1,10,50,000/- for the year under consideration. 7. Co....