2025 (10) TMI 284

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.... passed u/s 147/143(3) of the Income-tax Act, 1961 (hereinafter referred to as "the Act") dated 05.12.2018 by the Assessing Officer, ACIT, Circle- 7(1), New Delhi (hereinafter referred to as "ld. AO"). 2. The assessee had raised the following grounds of appeal before us:- "1. That in the absence of mandatory order u/s.127(1) and for failure of its communication to assessee for transferring of jurisdiction from ITO Ward-7 (1) New Delhi to ACIT, Circle-7 (1) New Delhi, the assumption of jurisdiction by ACIT Circle -7 (1) is illegal and unsustainable, making all proceedings including impugned asstt. order is without jurisdiction, null and void, illegal and unsustainable. 2. That under the facts and circumstances, of the ca....

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....filed its return of income on 30.09.2011 for AY 2011-12 declaring total income of Rs. 46,33,961/- which was duly processed u/s 143(1) of the Act and no scrutiny assessment was framed on the same. The assessee is engaged in the business of real estate development. The assessment was sought to be reopened u/s 147 of the Act on the basis of information received from DDIT (Inv.), Unit III, Gurgaon during a search action u/s 132 of the Act carried out in M/s Skylark Group of companies which showed that Rs 60,00,000/- has been received by the assessee company from KRAC Securities Pvt Ltd during the year under consideration. Accordingly, notice u/s 148 of the Act stood issued to the assessee on 30.3.2018. The reasons recorded for reopening the ass....