2025 (2) TMI 1713

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....Shrivastava, Sr. DR ORDER PER SATBEER SINGH GODARA, JUDICIAL MEMBER: This assessee's appeal for assessment year 2013-14, arises against the Commissioner of Income Tax (Appeals)-National Faceless Appeal Centre [in short, the "CIT(A)-NFAC"],Delhi's DIN and order no. ITBA/NFAC/S/250/2024-25/1069178761(1) dated 27.09.2024, involving proceedings under section 143(3) of the Income-tax Act, 1961....

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....he assessment year 2010-11 onwards upto the impugned assessment year was declared @ 0.46%, 1.55%, 1.2% and 3.11%, respectively. It is thus clear that the assessee's net profit rate in relevant previous year is already much higher than that accepted in all the preceding three assessment years. However, the fact remains that the assessee has not been able to plead and prove various expenses claimed ....