2026 (4) TMI 251

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....spondent : Ms. Harpreet Kaur Hansra, Sr. DR ORDER PER SATBEER SINGH GODARA, JM: This assessee's appeal for assessment year 2012-13 arises against the order of National Faceless Appeal Centre, Delhi dated 23.07.2025 (hereinafter referred as the 'First Appellate Authority'), Delhi's DIN and Order No. ITBA/NFAC/S/250/2025-26/1078793393(1), involving proceedings u/s 143(3) of the Income-tax A....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

..... CIT(A), erred in endorsing the Ld. Assessing Officer exercising the jurisdiction u/s 148 of the Act. 2.1 That on the facts and in circumstances of the case, Ld. CIT(A), erred in holding that: a) on perusal of reason recorded for issue of notice u/s 148, it is clear that the Assessing Officer has exercised his authority according to its own discretion." b) The informati....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....n account accommodation entries received from M/s Radhey Shyam Murari Lal and Co. and M/s Shree Shyam Overseas. 3.1 That on the facts and in circumstances of the case, the Ld. CIT (A) erroneously observed / holding the following which is against the facts on record: a) The Appellant have not made any effort to justify the sales transactions with the documents b) It was d....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... have failed to discharge the onus to prove this issue i.e. genuineness of sales. 4. That on the facts and in circumstances of the case, the Ld. CIT(A) erred upholding the levying the interest u/s 234A and 234B of the Act. 5. All the above grounds are independent and without prejudice to others. That the appellant carves the right to add, modify, amend and delete the grounds of a....