2025 (12) TMI 30

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....Income-tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as "CIT(A)" for short), both dated 23.09.2024, passed under Section 250 of the Income-tax Act, 1961 [hereinafter referred to as "the Act" for short], for Assessment Years (AY) 2017-18 & 2018-19. 2. Since the issues involved in these appeals are identical, they were heard together and are being disposed of by way of this common order for the sake of convenience. 3. For the purpose of adjudication, we shall take ITA No.2018/Ahd/2024 for AY 2017-18 as lead case. 4. The Revenue has raised following grounds of appeal :- "(a) The Ld. CIT(A) has erred in law and on facts in deleting the addition of Rs. 89,30,844/ out of Rs 99,23,160/- mad....

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.... the addition to the extent of Rs. 9,92,316/- representing 10% of gross profit on sales transactions aggregating to Rs. 99,23,160/- entered into with 12 customers as mentioned in decisive para 5(b) of the impugned assessment order. The said addition has been confirmed by Ld. CIT(A) on assumption basis." 6. We have heard the rival contentions and perused the material available on record. The primary issue raised by the assessee in its Cross-Objection pertains to the validity of notice issued u/s 148 of the Act for AY 2017-18 and AY 2018-19, wherein the wrong Sanctioning Authority has given approval for reopening of assessment beyond three years as specified in Section 151 of the Act. For better understanding, Section 151 is reproduced as ....