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2025 Supreme(Online)(ITAT) 2940

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
Sh. M. Balaganesh, ACJ, Sh. Sudhir Kumar, J
OM PRAKASH TANTIA FARIDABAD – Appellant
Versus
DCIT CENTRAL CIRCLE-25 NEW DELHI – Respondent


Advocates:
Dr. Kapil Goel, Advocate

JUDICIAL MEMBER:

These captioned appeals by the respective assessees are directed against the order of the Commissioner of Income Tax (Appeals)-29, New Delhi [hereinafter referred to as “CIT(A)”] vide order dated 01.05.2018 pertaining to A.Y. 2015-16 arises out of the assessment order dated 29.12.2017 of the Income – tax Act, 1961 [hereinafter referred as ‘the Act’].

2. Since, the issues are common and appeals are connected, therefore, they are heard together and are being disposed off by this common order. First, we take up ITA No.4737/Del/2018 A.Y. 2015-16 as lead case.

3. The assessee has raised the following grounds of appeal:

1. Jurisdictional ground: That both the assessment orders of Ld AO and first appellate order of ld CIT-A are bad in law as entire asst, is framed without authority of law and ultra vires to provisions of the 1961 Act (income tax act, 1961) being without jurisdiction as it is mainly/chiefly based on stated material as emanating from search action u/s 132 on "other person", so it is framed in violation of mandate of special and specific provision of Section 153C of 1961 Act

2. Total Violation of principle natural justice: That both the assessment orders of L

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