2025 (3) TMI 2104

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.... appellate Authority both on legal grounds as well as on the merits of the additions. Thus, grounds of appeal no. 1-3 are legal grounds regarding the jurisdictional insufficiency of the Ld. AO in invoking proceedings u/s 147 r.w.s 148 of the case and grounds of appeal no. 4-5 are challenging merits of the addition. As, grounds of appeal no. 1-3 are legal grounds regarding the jurisdictional insufficiency of the Ld. AO and they lie at the base of the controversy, the same are examined first. 3. The ld. Council of the assessee submitted that the entire controversy seminal to the grounds of appeal no. 1-3 are legal grounds regarding the jurisdictional insufficiency of the Ld. AO emanates from the fact that the Revenue, inspite of seized of ....

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...., Dwarka 110075, delhi" (page 1 of the paper book). 4. It is the case of the assessee that its assessment for AY 2011- 12 was conducted on 27.11.2018 at its Jhajjar address (page 32,33 of the paper book). The Ld. Council has submitted that, the AO to correct his mistake, during the assessment proceedings issued notice u/s 142(1) dated 29.07.2019 at its Jhajjar address. The Ld. Council submitted that during the assessment proceedings it had challenged the proceedings on the wrong address, which were overruled (page 66 of the paper book). The assessee furnished a screenshot of the ITD qua issue of the notice u/s 148 to show that there was no mention of its Jhajjar address. The Ld. Council placed reliance inter alia upon a catena of the jud....