IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES: F : NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER AND SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER Assessment Year: 2014-15 Carissa Investment Pvt. Ltd., Vs ACIT, B-97, 2^nd Floor, Circle-5(2), Amrit Puri, Garhi, New Delhi.

East of Kailash, New Delhi – 110 065. PAN: AAACC3277A ITA No.644/Del/2020 Assessment Year: 2014-15 ACIT, Vs. Carissa Investment Pvt. Ltd., Circle-5(2), B-97, 2^nd Floor, New Delhi Amrit Puri, Garhi, East of Kailash, New Delhi – 110 065. PAN: AAACC3277A (Appellant) (Respondent)

Assessee by : Shri Mayank Patawari, Advocate &

Shri Aakash Ojha, Advocate Revenue by : Ms Harpreet Kaur Hansra, Sr. DR Date of Hearing : 31.07.2025 Date of Pronouncement : 30.09.2025

ORDER

PER ANUBHAV SHARMA, JM These are cross appeals preferred by the assessee as well as the Revenue against the order dated 14.11.2019 of the Commissioner of Income-tax (Appeals)-31, New Delhi (hereinafter referred to as the ld. First Appellate Authority or ‘the Ld. FAA’ for short) in Appeal Nos.28/18-19/117/17-18 arising out of the appeal before it against the order dated 20.12.2016 passed u/s 143(3) of the Income Tax Act, 1961 (hereinafter referred as ‘the Act’) by the ACIT, Circle-5(2), New Delhi (hereinafter referred to as the Ld. AO).

2. At the time of hearing, the ld.AR primarily rested the case arguing ground No.2 which is reproduced below:-

“2. That the ld.CIT(A) has erred in law and on facts by considering that notice u/s 143(2) was served upon the appellant within the stipulated time in terms of the provision of section 282.”

3. This claim of the assessee has been countered by the Revenue by filing a report taken from the AO and as per the said report, the assessee, Carissa Investment Private Limited (PAN: AAACC3277A), is a private limited company engaged in investment-related activities. The return of income for the Assessment Year 2014-15 was filed electronically in Form ITR-6, verified and digitally signed by its Director, Shri Vinay Kumar Mehta, on 23.01.2023. The Income Tax Return Acknowledgement (Ack. No. 930776721230123) reflects the following registered address of the assessee:-

B-97, 2nd Floor, Amritpuri, Garhi, East of Kailash, New Delhi - 110065.

3.1 This address is consistent with the one available in the PAN database, as per latest ITR and the MCA (Ministry of Corporate Affairs) records.

Email IDs Associated with the Assessee

3.2 Two email addresses were prominently associated with the assessee during the relevant period:

• carissainvestment1234@yahoo.in - This email ID was available in the Income Tax Business Application (ITBA) system and was provided by the assessee while filing its return.

• altrainvestment@yahoo.com - This email ID appears on the official website of the Ministry of Corporate Affairs (MCA) under the contact details of Carissa Investment Private Limited. It is linked to the company's digital profile available to the public and to regulators.

3.3 Thus, both email IDs were traceable to and verifiably under the control of the assessee company.

Service of Notice u/s 143(2)

3.4 The Department issued notice u/s 143(2) on 18.09.2015, which was served on the assessee by the following valid and recognised modes:

• Email Communication: The notice was sent to both registered email IDs:

o carissainvestment1234@yahoo.in (as per ITBA)

o altrainvestment@yahoo.com (as per MCA website)

• Physical Delivery via Inspector: The notice was also physically delivered by the departmental inspector at the assessee’s registered office located at: B-97, 2nd Floor, Amritpuri, Garhi, East of Kailash, New Delhi - 110065.

This address was sourced from:  ITR-V for A.Y. 2014-15  . PAN database;

• MCA website records.

3.5 The mode and manner of service are compliant with the requirements of Section 282 of the Income-tax Act, 1961, and Rule 127 of the Income-tax Rules, 1962.

3.6 The contention of the ld. counsel are that the AO was repeatedly informed of the correct addresses, however, the same has not been taken note