2026 (4) TMI 176

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....esh Rupavatia, Sr.D.R. ORDER PER: T.R. SENTHIL KUMAR, JUDICIAL MEMBER This appeal is filed by the Assessee as against appellate order dated 11-09-2025 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, (in short referred to as "CIT(A)"), arising out of the assessment order passed under section 143(3)of the Income Tax Act, 1961 (hereinafter referred....

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.... to the reassessment order passed u/s 147 r.w.s. 144 of the Act, instead of the assessment framed u/s 143(3) of the Act in the case of your appellant. The impugned order so passed by Ld. CIT(A) u/s 250 of the Act thus suffers from a fundamental factual error and non-application of mind rendering it invalid, non-speaking, and liable to be quashed. 2. Without prejudice to the above, the Ld.....

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....) has erred in making addition u/s. 69B of the Act amounting to Rs. 3,00,000/- as unexplained investment without giving opportunity of being heard. It is submitted that the order passed is totally incorrect and illegal and the entire addition made on account of on-money be deleted. 5. The order passed by the Ld. CIT(A) is bad in law and contrary to the provisions of law and facts. It is s....

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.... order mistakenly passed by the appellate authority with same name and assessment year of the assessee. 5. We have perused the Grounds of Appeal raised by the assessee before Ld. CIT(A) which is against u/s. 143(3) order and against the addition of Rs. 98,57,600/- claimed as exempt u/s. 10(1)/10(37) of the Act. Whereas the issue in reassessment order is addition of Rs. 50,91,233/- as the loan t....