TaxTMI 
TaxTMI 
2026 (9) TMI 1449
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.... CIT(DR) ORDER PER SUDHIR KUMAR, JM : This appeal by the assessee is emanating from the order of the Ld. Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre, Delhi [hereinafter referred as CIT(A)] dated 22.12.2025 pertaining to assessment year 2017-18. Assessee has raised originally as many as 8 grounds of appeal. During the hearing, Ld. AR has also raised the following a....
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....valid and without jurisdiction and therefore deserve to be quashed as such and consequently impugned order of assessment dated 31.3.2025 u/s. 147 read with 144 of the Act is without jurisdiction and deserves to be quashed as such. 2. Ld. AR stated that the above additional grounds are purely legal in nature and goes to the root of the matter and in view of the Hon'ble Supreme Court decision in ....
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....ue of notice u/s. 148 of the Act and notice u/s. 143(2) of the Act, therefore, initiation of proceedings and consequential order of assessment u/s. 147 read with section 144 of the Act deserve to be quashed as such. 5. Ld. CIT(DR) relied upon the orders of the authorities below. 6. Considered the rival submissions and material placed on record. We observed that in this case notice dated 23.3....
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....4.2022. We further note from the reply dated 12.3.2024 of the assessee which is placed at (page no. 82-87 of the Paper Book) that it has been duly informed that M/s EMU Realcon (P) Ltd. stood merged with M/s Innus Infrastructure (P) Ltd.; however, despite thereof, AO has issued notice dated 23.3.2024 u/s. 148 of the Act (APB-Page 96) and notice dated 1.7.20224 u/s. 143(2) of the Act (pages 99-101 ....