2025 (12) TMI 498

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....venue : Shri Pradeep Dung Dung, Sr. DR ORDER PER RAJESH KUMAR, 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 30.01.2025 for the AY 2019-20. 2. The assessee has challenged the order of the learned CIT (A) on legal issue as well as on merit. 2.1. On legal issue the ass....

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.... FDRs which were given to Govt deptts. Later on the Sarfaesi proceedings u/s 132(2) of the Act of Sarfaesi Act, 2002 were initiated against the assessee and ultimately the bank took over the possession of the assessee's premises under the said Act. The learned AO initiated the reassessment proceedings u/s 147 of the Act by issuing notice u/s148 of the Act on 14.03.2023, after passing the order u/s....

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....e to know from the income tax department that TDS amounting to Rs. 10,77,882/- had cut in the F.Y. 2019-20 for FDs amounting to Rs. 1,67,21,259/-. The assessee requested the bank to supply the details of the same again on page 8. The learned AO extracted the letter dated 05.02.2024, written by the assessee to the verification unit that as per form no.26AS for A.Y. 2019-20, the Central Bank of Indi....

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....ed the order of the learned AO. 2.3. Having considered submissions and perusing the materials available on record, we find that the assessee's account was declared NPA following which security/guarantee given by the assessee in the form of FDRs with interest thereon to various institutions. We note that the bank has not responded to the various requests by the assessee. In these circumstances, ....