ORDER

Per Rajesh Kumar, AM

The present appeal arises from order dated 17.03.2022 passed u/s 250 of the Income Tax Act, 1961 (hereafter referred to as “the Act”) by the Ld. Commissioner of Income Tax (Appeals), [hereafter referred to as “the Ld. CIT(A)].

2. At the time of hearing, the Ld. Counsel for the assessee challenged the legality of notice issued u/s 148 of the Act on the ground that the same has been issued on wrong facts and without application of mind by the AO and therefore, the same is bad in law and so is the assessment framed consequently.

3. The facts in brief are that the assessee filed its return of income on 06.08.2018 declaring total income of Rs. 11,860/-. The case of the assessee was reopened u/s 147 read with section 148A of the Act on the basis information on insight portal that the assessee received Rs. 10,50,000/- during the year from M/s Rangoli Plaza Pvt. Ltd. which is shell company. Accordingly, the case of the assessee was reopened by the is