2025 (9) TMI 1704

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....e instance of assessee pertaining to A.Y. 2017-18 is directed against the order dated 19.12.2024 of National Faceless Appeal Centre (NFAC) Delhi passed u/s. 250 of the Income-tax Act, 1961 (hereinafter also called 'the Act') arising out of Assessment Order dated 26.03.2022 passed u/s. 147 r.w.s 144 of the Act. 2. Assessee has raised following grounds of appeal : "1. On the facts in the....

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....arding appellant's contention. Your appellant prays for deletion of entire addition Your appellant prays for deletion of entire addition. Your appellant craves for to add, alter amend, modify, delete any or all grounds of appeal before or during the course of hearing in the interest of natural justice." 2.1 Assessee has also raised an additional ground which reads as under : ....

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....eedings u/s. 153C of the Act and not u/s. 147 of the Act and therefore since valid assessment proceedings have not been initiated the same deserves to be quashed. 5. On the other hand, ld. Departmental Representative supported the order of ld.CIT(A). 6. I have heard the rival contentions and perused the material placed before me. The assessee in the instant case is an individual and did not ....

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....dated 19.09.2024 after considering earlier decision of this Tribunal in the case of ITO Vs. Narendra Sampatlal Bafna in ITA No. 688/PUN/2024 order dated 19.08.2024 has held that proper course by the Assessing Officer should have been under the provisions of section 153C of the Act and not under the provisions of section 147 of the Act as the case has been reopened on the basis of information ....