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2025 Supreme(Online)(ITAT) 1691

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
SHRI M. BALAGANESH, ACJ, SHRI YOGESH KUMAR U.S., J
GAJENDER KUMAR GURUGRAM – Appellant
Versus
ITO WARD-1(5) GURGAON – Respondent


Advocates:
Dr. Kapil Goel, Adv; Shri Rajesh Kumar Dhanesta, Sr. DR

Table of Content
1. appeals arise from nfac order (Para 1)
2. validity of assumption of jurisdiction (Para 2)
3. no return of income filed (Para 3)
4. sufficiency of reasons (Para 4)
5. appeal allowed for ay 2012-13 (Para 5 , 6)
6. both appeals allowed (Para 7)

ORDER

PER M. BALAGANESH, A. M.:

1. The appeals in ITA Nos. 3154 & 3155/Del/2023 for AYs 2012-13 and 2013-14, arise out of the order of the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as „ld. NFAC‟, in short] dated 08.09.2023 against the order of assessment passed u/s 147 r.w.s 144 of the Income-tax Act, 1961 (hereinafter referred to as „the Act‟) dated 22.04.2022 by the Assessing Officer, NWR-W-53(3) (hereinafter referred to as „ld. AO‟). Identical issues are involved in both these appeals, hence, they are taken up together and disposed off by this common order for the sake of convenience.

2. The first identical issue to be decided in this appeal is challenging the validity of assumption of jurisdiction u/s 147 of the Act.

3. We have heard the rival submissions and perused the material available on record. For AY 2012-13, no return of income has been filed by the assessee. The ld AO noted that on the basi

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