2026 (1) TMI 696

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.... New Delhi, dated 30.06.2025, in ITA No. 560/Del/2024 for A.Y. 2015-16. By that order, learned Tribunal has dismissed the revenue's appeal filed against the order of the Commissioner of Income Tax (Appeals) dated 13.12.2023 whereby CIT (Appeals) had allowed the assessee's appeal and set aside the reassessment order dated 30.3.2022 passed by the National Faceless Assessing Authority. 3. Present appeal has been preferred on the following question of law: "(i) Whether on the facts, circumstances and in law, the Ld. ITAT has erred in law in not appreciating that the return of income filed by the assessee in compliance to notice u/s 148 of the Income Tax Act 1961 on 25.05.2021 was neither filed within the stipulated time peri....

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....filed beyond the time allowed in the said notice and not being e-verified within the prescribed time? (v) Whether on the facts, circumstances and in law, the Ld. ITAT has erred in law in affirming the quashing of the assessment order passed u/s 147 r.w.s 144 r.w.s 144B of the Income Tax Act 1961 by overlooking the fact that the Assessment Order in this case was actually passed u/s 147 r.w.s 144 r.w.s 144B of the Income Tax Act, 1961 (as mentioned clearly in para 10 and para 11 of the Assessment Order dated 30/03/2022).?" 4. No other question of law has been framed or pressed during hearing of this appeal. 5. There is no challenge to the fact finding recorded by the CIT (Appeals) as confirmed by the Tribunal that the assessee ....