2026 (2) TMI 76

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....e National Faceless Appeal Centre, Delhi (NFAC) [ld. CIT(A)] dated 19.6.2025 wherein the appeal filed by the assessee against the reassessment order passed dated 30.12.2019 by the ITO, Ward 4(1)(4), Bangalore was partly allowed. Therefore, the assessee is in appeal before us. 2. The solitary ground in the appeal filed by the assessee is with respect to reopening the assessment and addition of Rs. 1,60,00,000 made u/s. 68 of the Act being loan obtained by the assessee from Royal Mirage Financial Consultants Pvt. Ltd., as the assessee failed to prove the genuineness of the transaction and further interest paid thereon along with commission on the above loan was confirmed by the ld. CIT(A). 3. During the course of hearing the assessee ha....

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....ecorded by the ld. AO at para 2 of the assessment order. Despite noting this, the ld. AO passed the reassessment order in the name of MRG Hotels Pvt. Ltd. [merged with World Resorts Ltd.] This order is challenged by the assessee stating that as on the date of the reassessment order, the above company viz., MRG Hotels Pvt. Ltd. was not at all existing, but still the reassessment order is passed in its name and therefore the passing of the reassessment order on a non-existent entity is invalid and deserves to be quashed. The ld. AR referred to the reassessment order stating the above facts. It was further stated that the order of the ld. CIT(A) has been passed in the name of World Resorts Ltd., but the assessment order is passed in the name o....