2026 (6) TMI 730

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....RA KAMBLE, J M: The appeal filed by the assessee is against the order passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [in short "CIT(A)"] dated 06.11.2025 for the Assessment Year (in short "AY") 2019-20. 2. The assessee has raised the following grounds of appeal: "1. The Ld. CIT(A) has erred in law as well as on fact by uphol....

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....urn of income on 18.07.2023 declaring total income of Rs. 29,41,766/-. Notice u/s 142(1) dated 20.06.2024 was issued alongwith questionnaire. The assessee filed reply dated 02.07.2024. The Assessing Officer observed that Shri Bharthbahi Trikamal Pandya is registered with Proprietory firm in the name of M/s Sunrise Enterprise with GST registered on 01.07.2017 and the status of the said GST was show....

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....register details, bank details showing payment through banking channel to Shri Bharatbhai Trikamal Pandya, GST Returns, details of godown, copy of ledger account of Shri Bharatbhai Trikamal Pandya maintained in the books of assessee, complete personal details such as PAN, address of Shri Bharatbhai Trikamal Pandya. The Ld. AR further submitted that Shri Bharatbhai Trikamal Pandya passed away on 19....

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....d due to his demise. These facts were brought on record by the son of the said Shri Bharatbhai Trikamal Pandya. Therefore, the conclusion of the Assessing Officer as well as CIT(A) that there was no response from seller cannot be held responsible under these circumstances. In fact, the assessee has stated the valid facts of the said party's demise during the very same year when the GST registratio....