2026 (2) TMI 632

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.... Shri Sumit Lalchandani, Adv. And Shri Utkarsa, Adv. For the Department : Shri Muneesh Rajani, Sr. DR ORDER PER NAVEEN CHANDRA, ACCOUNTANT MEMBER:- This appeal by the assessee is directed against the order of the ld. ld. CIT - 25, Delhi dated 27.01.2025 pertaining to A.Y 2013-14. 2. The sum and substance of the grievance of the assessee is that the assessment order passed u/s 147/14....

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....14 on the assessee company. In pursuant to the said proceedings, the assessment order u/s 153C/143(3) of the Act was passed on 26.11.2019 accepting the income declared in the return of income filed by the assessee company. 5. Subsequent to the assessment, the return was again selected for reassessment proceedings on the basis of information received form the Investigation Wing and notice u/s 14....

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....hemently stated that in the column of granting approval u/s 151 of the Act, the PCIT has only put a remark "As per Annexure". Further, the ld. AR pointed out to the said 'Annexure' to show that it contained the reasons recorded by the Assessing Officer to reopen the assessment and for seeking approval of the PCIT for reopening the case. In such a scenario, the ld. counsel for the assessee strongly....