2025 (10) TMI 855

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....AR, AM: This is an appeal preferred by the assessee against the order of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the "Ld. CIT(A)"] dated 19.03.2025 for the AY 2018-19. 02. The issue raised in ground no.1 by the assessee is against the order of learned CIT (A), NFAC, Delhi passed u/s 250 of the Act dated 19.03.2025 is bad in law and the same may be quashed. 0....

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....in the process of gathering material. However, the learned AO passed the final assessment order on 21.04.2021, making the addition of Rs.2,73,30,000/- to the total income of the assessee comprising addition u/s 56(2)(x) of the Act of Rs.2,50,00,000/- and addition u/s 68 of the Act read with section 115BBE of the Act of Rs.23,30,000/-. 04. In the appellate proceedings, the learned CIT (A) partly....

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....ddition if it is not ascertainable as to who is the real person who is liable to pay the tax. In other words, if the assessee is not in a position to ascertain on which person the tax is to be charged and recovered then the assessment is made on substantive basis on the person whom the learned AO believes that the tax should be levied and also makes addition on protective basis, where other than a....