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2025 Supreme(Online)(ITAT) 6755

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
Shri Challa Nagendra Prasad, J, Shri Avdhesh Kumar Mishra, ACJ
Aarti Bansal – Appellant
Versus
Income Tax Officer – Respondent


Advocates:
For the Appellant: Shri Suresh Gupta, CA
For the Respondent: Shri Ajay Kumar Arora, Sr. DR

आदेश /ORDER

PER C.N. PRASAD, J.M.

This appeal is filed by the Assessee against the order of the Ld. CIT(Appeals)-NFAC, dated15.10.2024 for the AY 2014-15. Assessee has raised the following grounds in her appeal: -

1. “On facts and circumstances of the case, the reassessment proceedings-initiated u/s 147 of IT Act by issue of notice dated 22.07.2022 u/s 148 of IT Act is barred by limitation and therefore, the reassessment proceedings and consequent reassessment order are void-ab-initio.

2. On the facts and circumstances of the case and also in law, the assessment proceedings and the assessment order both are bad in law and need to be quashed as no notice u/s 143(2) of IT Act was issued by the AO before completion of assessment proceedings against the return of income filed in response to notice u/s 148 of IT Act.

3. On facts and circumstances of the case, the reassessment proceedings have been initiated u/s 147/148/148A of IT Act without making compliance of provisions of sec 149(1) of IT Act and therefore, the reassessment proceedings and consequent reassessment order are needs to be quashed.

4. The impugned assessment is invalid and without jurisdiction as the said assessment has been

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