2025 (10) TMI 131

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....DR ORDER PER SATBEER SINGH GODARA, JM This Revenue's appeal for assessment year 2015-16, 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/250/2023-24/1061488408(1), dated 26.02.2024 involving proceedings under section 143(3) r.w.s. 147 of the Income-tax Act, 1961 (hereinafter referr....

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....s. 2,01,571/- representing dividends from mutual funds and share of profit from partnership firm; involving varying sums. The Revenue could hardly dispute that the assessee had already made suo motu disallowance of Rs. 8,33,419/- i.e. more than the exempt income itself, and, therefore, we hereby quote Joint Investment Pvt. Ltd. vs CIT (2015) 372 ITR 694 (Del.) to conclude that the CIT(A)/NFAC has ....