IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “SMC”, NEW DELHI BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT ITA No. 4366/Del/2025 (Asstt. Year : 2017-18)

Shri Malkiat Singh, vs.ITO, Ward 45(1), WZ 46/3B, Krishna Puri, New Delhi Gali No. 1, Tilak Nagar, Delhi – 110 018 (PAN:BSRPS2158H)

(Appellant) (Respondent)

Appellant by : Sh. P.K. Bansal, Adv. & Sh. Tarun Sharma, CA Respondent by : Ms. Harpreet Kaur Hansra, Sr. DR Date of Hearing 09.09.2025 Date of Pronouncement 08.10.2025 ORDER This appeal has been filed by the Assessee against the orderdated

16.06.2025passed by the NFAC, Delhi relating to assessment year 2017-18.

2. The first issue in this appeal of the assessee is as regards to order of NFAC confirming the action of the Assessing Officer in upholding the validity of reassessment proceedings initiated u/s. 147 r.w.s. 148 of the Act, although the reopening is barred by limitation being escaped income was less than Rs. 50 lacs and does not fall under the extended time limitation u/s. 149(1)(b) of the Act. For this, the assessee has raised the following two grounds:-

(i) That the NFAC has erred in law and on facts in upholding the validity of reassessment proceedings initiated under sec