IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “C”, NEW DELHI BEFORE SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER, AND SHRI SUDHIR PAREEK, JUDICIAL MEMBER ITA NO. 921/Del/2024 A.YR. : 2015-16 KANPUR DEVELOPMENT AUTHORITY, VS. DCIT, EXEMPTION CIRCLE, 1^ST FLOOR, KDA BUILDING, GHAZIABAD BENAJHABAR ROAD MOTI JHEEL, KANPUR, UP-208002 (PAN: AAALK0324M)

(APPELLANT) (RESPONDENT)

Assessee by : Dr. Rakesh Gupta, Adv. & Sh. Somil Agarwal, Adv. & Ms. Shilpa Gupta, CA Department by : S hri Dayainder Singh Sidhu, CIT(DR)

Date of hearing : 20.03.2025 Date of pronouncement : 26.03.2025 ORDER PER SHAMIM YAHYA, AM :

Assessee has filed the Appeal against the order dated 28.12.2023 passed by the Ld.

NFAC, Delhi relating to assessment year 2015-16 on the following grounds:-

1. That having regard to the facts and circumstances of the case, assumption of jurisdiction in initiating the proceedings u/s 147 and passing the impugned reassessment order us 147/144B and that too without complying with mandatory conditions u/s 147 to 151A as envisaged under the Income Tax Act, 1961, is bad in law and against the facts and circumstances of the case.

2. That in any case and in any view of the matter, assumption of jurisdiction