2026 (5) TMI 293

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....r the Revenue : Shri Rajesh Kumar Dhanesta, Sr. DR ORDER PER SANJAY AWASTHI, ACCOUNTANT MEMBER: 1. The present appeal arises from order dated 28.08.2025, passed u/s 250 of the Income Tax Act, 1961 (hereafter as "the Act"), by Ld. CIT(A)- NFAC, Delhi. In this case, while the impugned addition pertains to an amount of Rs. 7 lakhs disallowed by way of a deduction claimed by the assessee u/s ....

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.... the face of approval u/s 151 at SN-9. * Approval u/s 151(ii) of PCIT has been taken instead of PCCIT [while passing order dt 02-05-2023 u/s 148A(d)], as more than 3 Years have been lapsed from the end of relevant AY as the fact has been accepted fey Ld AO at the face of approval u/s 151 at SN-9" 2. That on the facts and in the circumstances of the case and in law, Ld CIT(A) eare....

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....om the PCIT-Faridabad instead of the Pr. Chief Commissioner since the matter was older than three years from the end of the relevant assessment year, being AY 2019-20. The Ld. AR pointed out the chronology of event as under: - a) First notice u/s 148A(b) of the Act was issued on 19.04.2023; b) Notice u/s 148 of the Act was issued on 02.05.2023. It was pointed out that this notice....