IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES: C : NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI ANUBHAV SHARMA, JUDICIAL MEMBER Assessment Year: 2019-20 Janardhan Kapur, Vs ITO, C/o Sanjiv Sapra & Associates LLP, Ward-29(1), Chartered Accountants, Delhi.

C-763, New Friends Colony, New Delhi – 110 025.

PAN: AOJPK8128G (Appellant) (Respondent)

Assessee by : Shri Sanjiv Sapra, FCA Revenue by : Shri Om Parkash, Sr. DR Date of Hearing : 28.04.2025 Date of Pronouncement : 09.05.2025

ORDER

PER ANUBHAV SHARMA, JM This appeal is preferred by the Assessee against the order dated

13.09.2024 of the Commissioner of Income-tax (Appeals), NFAC, Delhi (hereinafter referred to as the Ld. First Appellate Authority or ‘the Ld. FAA’, for short) in Appeal No.NFAC/2018-19/10092978 arising out of the appeal before it against the order dated 23.09.2021 passed u/s 143(3) r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) by the Assessment Unit, Income-tax Department (hereinafter referred to as the Ld. AO).

2. On hearing both the sides, we find that amongst other grounds on merits the assessee has raised ground No.2. This ground was not raised before the CIT(