IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER Assessment Year: 2012-13 Assessment Year: 2012-13 Assessment Year: 2012-13 Assessment Year: 2012-13 Assessment Year: 2012-13 Assessment Year: 2012-13 Assessment Year: 2012-13 Assessment Year: 2012-13 Assessment Year: 2012-13 Assessee by Sh. Ankit Kumar, Adv.

Department by Sh. Manoj Kumar, Sr. DR Date of hearing 19.01.2026 Date of pronouncement 19.01.2026

ORDER

This assessee’s appeal for assessment year 2012-13, arises against the Commissioner of Income Tax (Appeals)-3 [in short, the “CIT(A)”], Gurgaon’s order dated 11.11.2025 passed in case no. 11089/CIT(A)-3/GGN/2019-20, involving proceedings under section 143(3)/147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).

Heard both the parties. Case file perused.

2. Coming to the first and foremost issue of validity of learned ITO, Ward-19(2), Delhi’s assessment framed on 26.12.2019, learned counsel quotes the CBDT’s landmark circular No. 1 of 2011 that going by the pecuniary jurisdiction of the departmental authorities for the purpose of framing assessment, it is clear that any return involving more than