2026 (5) TMI 305

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....ing regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in upholding the action of AO in reopening the assessment u/s. 147 and that too without complying with mandatory statutory requirement of section 147 to 151A of the Act, more so when jurisdiction was not assumed as per law. 2. That in any case and in any view of the matter, that reopening of the impugned assessment and framing of impugned assessment order are bad in law and against the fact and circumstances of the case. 3. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in upholding the action of the AO that in this case order u/s. 148A(d), dated 5.4.2022 and notice u/s. 1....

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....Industrial Estate, Faridabad, jointly sold for Rs. 4 crore). Information of this high value transaction was flagged under the CBDT's Risk Management Strategy (NMS). Accordingly, notice u/s. 148A(b) was issued on 23.2.2022, but as no reply was filed, order u/s. 148A(d) and notice u/s. 148 were issued on 5.4.2022. Subsequently, the case was assigned to the Faceless Assessment Unit u/s. 144B. The assessee filed his return belatedly on 28.2.2023 declaring total income of Rs. 68,20,080/- under the head Long Term Capital Gains. During assessment, several notices u/s. 142(1) and 143(2) were issued; partial responses were received. The assessee submitted sale and purchase deeds, bank statement showing deposit of sale proceeds, and computation of in....