2026 (5) TMI 1769

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....& Shri Tarun Chanana, Adv For the Revenue : Shri Ajay Kumar Arora, Sr. DR ORDER PER SANJAY AWASTHI, ACCOUNTANT MEMBER: 1. The present appeal arises from order dated 27.11.2025, passed u/s 250 of the Income Tax Act, 1961 (hereafter as "the Act"), by Ld. CIT(A)-NFAC, Delhi. In this matter, the case was reopened on the basis of information received from the Investigation Wing. The said in....

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....nds pertaining to the merit. The Ld. AR filed a chart of dates, through which it was explained that following the Hon'ble Apex Court's judgment in the case of Rajeev Bansal reported in 167 taxmann.com 70 (SC), a notice u/s 148 could have been issued by 14.06.2022, whereas it was actually issued on 30.06.2022. The Ld. AR relied on the table of events prepared by him and took us through the relevant....

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....fourth proviso to section 149 of the Act. 7 Days Paras 109-113 6. Period of deemed stay to be excluded as per 3rd proviso to section 149 [Date of Original 148 till date allowed to file a reply to assessee] 24.06.2021 to 07.06.2022 Paras 105-107 7. Last date for issuing notice u/s 148 [i.e., 07.06.2022 + 7 days] 14.06.2022 Para 77 8. Actual date of issuance of no....