2025 (3) TMI 2113

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.... Tripathi, Sr. DR ORDER PER AMITABH SHUKLA, AM: This appeal by Assessee is directed against the order of National Faceless Appeal Centre, Delhi, [for short hereinafter referred to as the ["Ld. CIT(A)"] dated 08.12.2023 for Assessment Year 2011-12. 2.0 The assessee has raised altogether 14 grounds of appeal agitating addition of Rs. 1,36,00,000/- made by the Ld. AO in his order u/s 143(....

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....ase to Delhi and had been assessed there by the department since 2009-10. It was submitted that for this year alone, inspite of clear information of the assessee being assessed in Delhi, the Ld. AO at Faridabad assumed illegal jurisdiction and passed the impugned assessment order u/s 143(3) r.w.s. 147 dated 28.12.2018. The Ld. Council as place on record a voluminous paper book to press its point t....

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....that inspite of these clear evidences, the objections of the assessee had been summarily overruled by the Ld. AO as well as the First Appellate Authority. The Appellant assessee has invited attention to the order u/s 154 for A.Y 2009-10 dated 05.12.2013 where again the Ld. AO admits that the assessee was operating from its Delhi address. Before us, the Ld. Council for the assessee has also filed a....

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....on over the assessee was shifted from ITO ward 1(1), Faridabad to ITO ward 1(4), Delhi. The assessee had been filing return of income from A.Y. 2010-11, from its Delhi address and the said fact was recognised by the department as evidenced from its orders mentioned supra. In this view of things, the action of the Ld. AO at Faridabad in acquiring jurisdiction over the assessee becomes questionable ....