2025 (3) TMI 1830

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....s out of the order of the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as 'ld. NFAC', in short] dated 24.03.2024 against the order of assessment passed u/s 144 of the Income-tax Act, 1961 dated 21.12.2019 (hereinafter referred to as 'the Act') by ITO, Ward-46(1), Delhi (hereinafter referred to as 'ld. AO'). 2. None appeared on behalf of the assessee despite issuance of....

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....s sought to be reopened vide issuance of notice under section 148 of the Act by the learned AO. No return of income was filed in response to the said notice under section 148 of the Act. The assessee through the authorised representative's letter dated 7-6-2019 submitted that the firm M/s National Steels was converted into a proprietary concern in the year 2002 and as such no status of a firm exis....

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....ment order. The learned AO during the course of assessment proceedings recorded a statement on oath from Shri Kishan Lakhani on 12-12-2019 wherein he was specifically asked in respect of issue of status of M/s National Steels and purchases made from M/s Global Suppliers. Mr. Kishan Lakhani stated that he is the proprietor of M/s National Steels since 2002 and filing his income tax return by using ....

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....sessee referred an appeal and reiterated that the firm was never in existence since 2002, but still the learned NFAC upheld the action of the learned AO. It is crystal clear from the aforesaid narration of facts that the firm had dissolved in the year 2002. Even though the PAN of the firm was active, but still no activities were carried out in the name of the said firm. The assessee had also state....