2025 (5) TMI 2215

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....R VIMAL KUMAR, JUDICIAL MEMBER: The appeal filed by the appellant/assessee is against order dated 25.10.2024 of the Learned Commissioner of Income-Tax (Appeals)/National Faceless Appeal Centre(NFAC), Delhi (hereinafter referred as 'Ld. CIT(A)') arising out of assessment order dated 24.12.2019 under Section 144 r.w.s. 147 of the Income-Tax Act, 1961 (hereinafter referred as "the Act") of the ACI....

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.... dated 24.12.2019, made addition of Rs. 8,38,50,800/-. 3. Against order dated 24.12.2019, appellant/assessee filed appeal before the Ld. CIT(A). Through order dated 25.10.2024, Ld. CIT(A) set aside order dated 24.12.2019 with the directions to the Ld. AO to frame the assessment order afresh after giving adequate opportunity of being heard to the appellant/assessee. 4. Being aggrieved, the ap....

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....ed to issue mandatory notice under Section 143(2) of the Act. Ld. CIT(A) further erred in not appreciating the detailed submissions duly corroborated and substantiated with cogent documentary evidences made by the appellant/assessee which negated the adverse inference drawn and contentions of the Ld. AO that form the basis of addition of Rs. 8,38,50,800/- to the total income of the appellant/asses....

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.... by the assessee, during assessment proceedings, passed order dated 24.12.2019 under Section 144 read with section 147 of the Act. Ld. CIT(A) in order dated 25.10.2024, as per proviso to section 251, sub-section (1) clause (a) of the Act, set aside the assessment order passed under Section 144 r.w.s. 147 of the Act and remand the matter back to the Ld. AO for making fresh assessment. The arguments....