आदेश/ORDER

PER S. R. RAGHUNATHA, AM:

This appeal by the revenue is filed against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, for the assessment year 2015-16, dated 28.05.2025.

2. The Revenue has raised the following effective grounds:

1. The Ld. CIT(A) erred in law and on facts in deleting the addition made towards capital gains.

2. The Ld. CIT(A) erred in admitting additional evidence without remanding the same to the Assessing Officer, in violation of Rule 46A of the Income-tax Rules, 1962.

3. The Ld. CIT(A) ought to have restored the order of the Assessing Officer.

3. The brief facts emanating from the records are that the assessee is an individual filed his return of income for A.Y.2015-16 on 31.10.2015, declaring total income of Rs.9,71,540/-. The return was processed u/s.143(1) of the Act and subsequently assessed u/s.143(3) of the Act on 27.09.2017, assessing income at Rs.72,66,560/-.

4. Later, the assessment was reopened u/s.147 of the Act, and reassessment was completed u/s.144 r.w.s. 144B of the Act on 28.03.2022, making the following additions:

i) Disallowance u/s.40(a)(ia) of Rs.2,68,449/- for alleged non-deduction of T