IN THE INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘E’ NEW DELHI)

BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER ITA No. 3454/DE/2025 (A.Y. 2018-19)

ORDER PER YOGESH KUMAR, U.S. JM:

The present appeal is filed by the Assessee against the order of the Commissioner of Income Tax (Appeals)-30, New Delhi [‘Ld. CIT(A)’ for short] dated 31/03/2025 pertaining to Assessment Year 2018-19.

2. The grounds of Appeal are as under:-

1. That on facts and circumstances of the case, the Ld. CIT(A) has erred in law as well as on facts in not quashing the assessment order dated 31.03.2023 passed under section 147 r.w.s 144B by Ld.AO, which is beyond jurisdiction, bad in law and void ab initio. 2. The Ld. CIT(A) has erred in law and on facts in upholding the validity of reassessment proceedings initiated under section 147 of the Act, despite the absence of any fresh tangible material or valid "information" as required under section 148 and Explanation 1 thereto, as the entire reopening was based on a mere borrowed satisfaction and mechanical reproduction of findings of the Investigation Wing without independent application of mind by the Assessing Officer (