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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
M. Balaganesh, AM, Mahavir Singh, VP
NEWS BUILDERS AND DEVELOPERS PRIVATE LIMITED DELHI – Appellant
Versus
INCOME TAX OFFICER DELHI – Respondent
| Table of Content |
|---|
| 1. the appeal concerns reopening assessments and evidentiary standards. (Para 1 , 4 , 5) |
| 2. the legitimacy of reliance on unsigned documents for tax reassessment is questioned. (Para 2 , 7 , 8) |
| 3. the court affirms that reopening requires substantive, corroborative evidence. (Para 9 , 10) |
| 4. final determination on assessment outcome based on evidentiary evaluation. (Para 11 , 12) |
ORDER
PER M. BALAGANESH, AM
1. The appeal in ITA No.1769/Del/2024 for AY 2009-10, arises out of the order of the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as „ld. NFAC‟, in short] in Appeal No. ITBA/NFAC/S/250/2023- 24/1061128269(1) dated 19.02.2024 against the order of assessment passed u/s 147 of the Income-tax Act, 1961 (hereinafter referred to as „the Act‟) dated 26.12.2016 by the Assessing Officer, ITO, Ward-18(2), New Delhi (hereinafter referred to as „ld. AO‟).
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2. The assessee has raised the following grounds of appeal:-
“1. That, on the facts and the circumstances of the case and in law and material available on record, the action of the Ld. CIT(Appeal) is arbitrary, without application of mind and gross violation of the principle of natural justice and on t
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