2025 (10) TMI 1154

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....il Kumar Kulheri, Sr. DR ORDER PER NAVEEN CHANDRA, AM :- This appeal by the assessee is directed against the order of the NFAC, Delhi dated 21.01.2025 pertaining to A.Y 2014-15. 2. The assessee has raised as many as 5 grounds of appeal. However, the solitary grievance argued before us is with regard to validity of the approval u/s 151 of the Income-tax Act, 1961 [the Act, for short] as....

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....he ld AR further argued that the assessee had requested for an opportunity to cross examine the revenue's witness whose statement was recorded behind the back of the assessee. However, no opportunity was granted to the assessee to cross examine the revenue's witness. 5. Per contra, the ld. DR relied upon the orders of the authorities below. The ld DR did not controvert the factual aspect of the....

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....have lapsed from the end of the relevant assessment year, would be PCCIT/CCIT. Notice in the present appeal has been issued with the approval of the PCIT-7 Delhi which is in violation of the provisions of section 151(ii) r.w explanation to section 148A. 7. The issue of legality of reopening of assessment under the amended provisions of section 148, 148A, 149 and 151 has been answered by the Hon....