2025 (3) TMI 1739

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....3026/Del/2024 for AY 2015-16 arises out of the order of National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as 'ld. NFAC', in short] in Appeal No. ITBA/NFAC/S/250/2024- 25/1065350445(1) dated 03.06.2024 against the order of assessment passed u/s 147 r.w.s. 144 of the Income-tax Act, 1961 dated 25.03.2022 (hereinafter referred to as 'the Act') by NFAC, Delhi (hereinafter referred....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....made investment of Rs. 24,38,508/- in Piyush Group. Similar assessment for AY 2014-15 was also reopened for the very same investment made in Piyush Group of Rs. 24,38,508/-. The assessee objected to the validity of reopening of stating that the ld AO was not even aware as to which year the information relating to investment was made by the assessee pertains to. The assessee sought for the reasons ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....d issued to the assessee in the present case. Now question that arises for my consideration is whether framing of reassessment order without issuance of notice u/s 143(2) of the Act would prove fatal to the assessment proceedings or not. This issue is no longer res integra in view of the decision of the Hon'ble Supreme Court in the case of CIT Vs. Hotel Bluemoon reported in 321 ITR 362 wherein....