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2026 Supreme(Online)(ITAT) 1525

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
MADHUMITA ROY, Judicial Member, BRAJESH KUMAR SINGH, Accountant Member
RAJPUT MOHAMMADMUNTASIM TASHBIHUDDIN DELHI – Appellant
Versus
INCOME TAX OFFICER DELHI – Respondent


Advocates:
For the Appellants/Petitioners: Sanjay Gupta, CA
For the Respondents: Manish Gupta, Sr. DR

Table of Content
1. foreign remittances received as export advances. (Para 1 , 2)
2. ao added unexplained income u/s 69a. (Para 3)
3. assessee challenges reopening and addition. (Para 4)
4. reopening proceedings validly initiated. (Para 5)
5. notice service on e-portal inadequate. (Para 6 , 7 , 8)
6. matter remanded for fresh consideration. (Para 9 , 10)

ORDER

PER BRAJESH KUMAR SINGH, AM:

This appeal has been preferred by the assessee against the order dated 21.04.2025 of the National Faceless Appeal Centre (NFAC) [hereinafter referred to as the ‘Ld. CIT(A)] Delhi, pertaining to Assessment Year 2018-19, arising out of Assessment order dated 17.03.2023 passed under Section 147 r.w.s.144B of the Income-tax Act, 1961(hereinafter referred to as ‘the Act’).

2. Brief facts of the case: The assessee was in receipt of foreign remittances to the tune of the Rs. 1,58,83,009/- in his bank account maintained with the J & K Bank during the F.Y. 2017-18 relevant to the A.Y 2018-19. The assessee submitted before the Ld. AO that he had received an export order for supply of textile item, against the same the assessee had received advance payment amounting to Rs. 1,58,91,562/- on 17th July 2017 and on 10th A

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