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2026 Supreme(Online)(ITAT) 4115

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
S. Rifaur Rahman, Accountant Member, Sudhir Kumar, Judicial Member
Mahavir Trading Co – Appellant
Versus
ACIT (Now Known as Shree Jaina Rice And Estates Pvt. Ltd.) – Respondent


Advocates:
For the Appellants/Petitioners: S K Gupta, CA
For the Respondents: Monika Singh, CIT-DR

Table of Content
1. reassessment initiated on non-filing despite transactions. (Para 1 , 2 , 3 , 4)
2. assessee challenges jurisdiction on dissolved firm. (Para 5 , 6)
3. revenue defends pan and form 26as activity. (Para 7)
4. tribunal notes dissolution but pan usage persists. (Para 8 , 9 , 10 , 11)
5. remit to verify form 26as income declaration. (Para 12 , 13 , 14)

ORDER

PER S. RIFAUR RAHMAN, ACCOUNTANT MEMBER :

1. This appeal is filed by the assessee against the order of Ld. Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to ‘ld. CIT(A)’) dated 19.05.2025 for AY 2013-14.

2. Brief facts of the case are, the Assessing Officer observed that based on the information available with the department that assessee is a firm having PAN No.AAIFM7522P has not filed its return of income for the assessment year 2013-14 which is evident from the e-filing history and the relevant history is reproduced at page 1 of the assessment order. Based on the information available with the department, the Assessing Officer observed that:-

a) As per Form 26AS assessee firm has earned contractual receipts of Rs.21,58,15,974/- during the year.

b) Assessee firm de

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