2026 (8) TMI 951

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.... arising out of the assessment order dated 12.03.2025 u/s 147 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') passed by DCIT, CC-6, New Delhi, for AY: 2016-17. 2. On hearing both sides we find that assessee has not pressed ground No. 1.1 & 1.2 and vide ground No.2.1 assessee has challenged the assumption of jurisdiction by questioning the manner in which the jurisdiction was assumed by ld. Assessing Officer u/s 148 of the Act by recording reasons which were not on the basis of any independent inquiry and non-application of mind. 3. In this context our attention was drawn to the fact that on the basis of information received from insight portal the case of assessee were opened and at page No. 1-2 and page No. 3-4 ass....

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....16 out of which an amount of Rs. 45,50,357/- was received in cash which has been recorded in the books of accounts and no other amounts was received. This discrepancy was pointed out on the basis of information from insight portal as made available to the assessee. 6. We find that thereafter in the assessment order it is recorded that the reply of the assessee to notice u/s 148A(b) of the Act was perused and examined and thereafter the proceedings were dropped on 11.04.2023 after taking prior approval of the specified authority as the case of assessee was covered under the provisions of Explanation 2 sub-clause (iv) of Section 148 of the Act. However, again instead, notice u/s 148 dt. 13.04.2023 was issued and the reasons recorded once a....