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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
Yogesh Kumar, U.S., JM, Manish Agarwal, AM
Department of Revenue – Appellant
Versus
RBA Buildtech Pvt. Ltd. – Respondent
| Table of Content |
|---|
| 1. brief facts stating losses and assessments. (Para 2 , 3) |
| 2. arguments regarding notice validity and procedural compliance. (Para 4 , 5) |
| 3. discussion on procedural adherence and legal interpretation of notice issuance. (Para 6 , 7 , 8 , 9) |
| 4. ruling on invalid notice and assessment consequences. (Para 10) |
| 5. final decisions and dismissal of the revenue appeal. (Para 11 , 12) |
ORDER
PER YOGESH KUMAR, U.S. JM:
The present appeal is filed by the Assessee against the order of Ld. Commissioner of Income Tax (Appeals)-3 Noida (‘Ld. CIT(A)’ for short), New Delhi dated 17/10/2024 for the Assessment Year 2016- 17.
2. Brief facts of the case are that, the assessee filed its return of income for A.Y. 2016-17 declaring loss at NIL. Regular assessment u/s 143(3) of the Income Tax Act, 1961 ('Act' for short) was finalized vide order dated 27/12/2018 accepting the loss declared by the Assessee. Thereafter, it is found from the information in possession with the department that, the assessee RBA Buildtech Pvt. Ltd. entered into LLP in the name and style of M/s AR Landcraft LLP and there were various high value transactions. Accordingly, after recording the reason for reopening a notice
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