2026 (3) TMI 543

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....anish Gupta, Sr. DR ORDER PER NAVEEN CHANDRA [A. M]: The above captioned appeal is preferred by the assessee against the orders dated 31.07.2025, by Ld. CIT(A)/NFAC, Delhi u/s. 250 of the Income Tax Act, 1961 [hereinafter referred to as, "Act"] for A.Y. 2013-14. The assessment is framed by the Assessing Officer [for shot, AO] u/s. 147 r.w.s 144 of the Act. 2. The assessee has raised fo....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....dentification Number ("DIN"), hence invalid and bad in law. 4. That the Ld CIT(A) has erred on facts and in law in confirming the assessment order on the basis of notice issued under section 148, dated 29.07.2022 issued by the Jurisdictional Assessing Officer as appros the NFAC. 5. That the Ld. CIT(A) has erred on facts and in law in confirming the action of the AO in treating Lo....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ssued on 28.06.2021 which as per the decision of the Hon'ble Supreme Court in the case of Ashish Aggarwal (2022 SCC Online SC 543) was considered as show cause notice. Thereafter, the AO initiated show cause u/s. 148A(b) dated 29.05.2022 of the Act in response to which the assessee replied vide letter dated 08.06.2022 received by the AO on 10.06.2022. The AO passed order u/s. 148A(d) and issued no....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ed on 28.06.2021 giving a surviving period, calculated according to the Rajeev Bansal decision, from date of issuance of deemed show cause notice till expiry of period as extended by TOLA (i.e., from 28.06.2021 to 30.06.2021), of 2 days. In response to the SCN dated 29.05.2022, the assessee filed its reply on 10.06.2022 which means the AO had to issue order u/s. 148A(d) as well as notice u/s. 148 ....