2026 (5) TMI 832

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....he Respondent : Sh. Manish Gupta, Sr. DR ORDER PER ANUBHAV SHARMA, JM: This appeal is preferred by the assessee against the order dated 22.07.2025 of the Ld. National Faceless Appeal Centre (NFAC) Delhi (hereinafter referred as Ld. First Appellate Authority or in short Ld. 'FAA') in DIN & Order No.: ITBA/NFAC/S/250/2025-26/1078771895(1) arising out of the order dated 24.12.2018 u/s 147 r.....

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....tion entries. 3. We have gone through the assessment order and the paper book filed by the assessee and we find that the only allegation of the AO is that during the year under consideration, the assessee has received accommodation entries of Rs. 64,20,000/- from the 3 parties, namely, M/s. Sai Enterprises : Rs. 10,00,000/-, M/s. Bharat Overseas: Rs. 40,00,000/-, M/s. NavDurga Trading Company: ....

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....said concerns in the year under consideration. 4. Ld. DR could not dispute the aforesaid facts emanating from the material before us and relied on the decision of Hon'ble Delhi High Court in ChetanSabharwal Vs. ACIT, Circle 28(1) (2019) 110 taxmann.com 57 (Delhi) and ReymondWollenMills Ltd. Vs. ITO, (1999) 236 ITR 34 (SC) to contend that investigation report can be relied for reopening. However....