2025 (8) TMI 872

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....l for assessment year 2012-13, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the "CIT(A)/NFAC"], Delhi's DIN and order no. ITBA/NFAC/S/250/2024-25/1065934259(1), dated 22.06.2024 involving proceedings under section 143(3) r.w.s 147 of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'). 2. Case called twice. None appears at the as....

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....onsideration to the assessee's pleadings and Revenue's foregoing contentions and see no reason to sustain the disallowance in entirety. This is for the precise reason that the facts emanating from the case file indeed indicate that the assessee's plot(s) hereinabove had indeed incurred expenditure; be it 11/1139/1 or 3/1134/1 (supra) and the department could not dispute that once the said former c....