2025 (2) TMI 1972

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....For the Assessee : Shri K. M. Gupta, Adv. and Ms. Shruti Khimta, AR For the Respondent : Shri Dharam Veer Singh, CIT-D.R. ORDER PER BENCH : 1. Both Assessee's appeals are against different orders dated 20.08.2024 and 21.08.2024 of the Learned Commissioner of Income Tax (Appeals)-NFAC, Delhi [hereinafter referred to as 'Ld. CIT(A)'] under section 250 of the Income Tax Act, 1961 [hereina....

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....he case was selected for complete scrutiny through CASS. Notice under section 143(2) was issued. Notices under section 142(1) were issued. Assessee e-filed necessary information and details. Reference under section 92CA(1) of the Act was made to the Transfer Pricing Officer, New Delhi with the prior approval of Pr. CIT, Gurugram for determining the Arm's Length Price under section 92CA(3) of the A....

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.....06.2021, assessee filed appeal before CIT(A) which was dismissed vide order dated 20.08.2024. 5. Being aggrieved, appellant/assessee preferred present appeal. 6. Learned Authorized Representative for appellant/assessee submitted that learned CIT(A) passed order under section 250 of the Act without jurisdiction. Learned CIT(A) erred in passing a nonspeaking order which is arbitrary, contrary....

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.....2024. Learned CIT(A) failed to take into consideration the submission/request to transfer the appeal to CIT(A), Delhi-44 in accordance with notification No. 113/2022 dated Oct 13, 2022 and decided the merit incorrectly by holding that the assessment order appeal is in pursuance to direction of DRP, although appellant/assessee had not filed any objection before the DRP. In view of the above materi....