2025 (6) TMI 2102

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....al, Advocate For The Revenue: Shri Ashish Tripathi, Sr. Dr ORDER PER S.RIFAUR RAHMAN, ACCOUNTANT MEMBER : 1. The assessee has filed appeal against the order of ld. Commissioner of Income-tax Appeals-23, New Delhi [hereinafter referred to as 'ld. CIT (A)] dated 16.03.2024 for Assessment Year 2015-16. 2. At the time of hearing, ld. AR of the assessee raised a jurisdictional issue of r....

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....ings. Further he brought to our notice page 375 of the paper book which is a letter issued by the AO forwarding copy of satisfaction recorded for reopening u/s 148 of the Act and brought to our notice page 377 of the paper book which is the detailed reasons forwarded to the assessee. Further he brought to our notice page 379 which is the acknowledgement of filing of reply by the assessee through e....

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.... in his order. He submitted that the assessment was passed vide order dated 29.03.2022 whereas the objections were disposed off only on 07.03.2024. He prayed that as per the provisions of section 148 and also decision of Hon'ble Supreme Court in the case of CIT v. Kelvinator of India Ltd.: 320 ITR 561 (SC), it is mandate and duty of the AO to dispose off the objections raised by the assessee befor....

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..../s 148 by recording the reasons and the same was supplied to the assessee on request. Assessee has raised several objections which were filed through e-portal vide acknowledgement dated 22.03.2022 and there is no record brought on record by the Departmental Representative of disposing off the objections before passing or initiating the reassessment proceedings. It is brought to our notice that the....