ORDER

PER SANDEEP SINGH KARHAIL, J.M.

The assessee has filed the present appeal challenging the impugned order dated 04/09/2024 passed under section 250 of the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [“learned CIT(A)”], for the assessment year 2016-17.

2. In this appeal, the assessee has raised the following grounds: –

“1. On the facts and in the circumstances of the case and in law, the Learned Commissioner of Income-tax (Appeals) (CIT") erred in not adjudicating the grounds raised by appellant and pertaining to (a) retraction of statement of Bijal Ashok Shah recorded during the course of survey and (b) the Assessing Officer ("AO") disregarding the order of the Hon. ITAT passed in the case of Bijal Ashok Shah. The CIT further erred in confirming the action of the AO to re-open the assessment by issuing notice u/s. 148 of the Income tax Act, 1961 ("the Act").

2. On the facts and in the circumstances of the case and in law, the CIT erred in confirming the addition of Rs. 3,62,45,000/- made by the AO under section 69C of the Act by stating that the transactions are only paper transactions that the appella