IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘E’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER Assessment Year: 2012-13 Sh. Rajesh Kapoor, Vs. ACIT, 4067, Naya Bazar, Circle-47(1), Delhi-06 New Delhi PAN: AAMPK0063B (Appellant) (Respondent)

Assessee by Sh. Ramesh Goel, CA Sh. Ratan Lal Goel, Adv.

Department by Ms. Amisha S. Gupta, CIT(DR)

Date of hearing 01.12.2025 Date of pronouncement 01.12.2025

ORDER

PER SATBEER SINGH GODARA, JM This assessee’s appeal for assessment year 2012-13, arises against the Commissioner of Income Tax (Appeals)-24 [in short, the “CIT(A)”], New Delhi’s order dated 18.11.2024 passed in case no. CIT(A), Delhi-16/10011/2020-21, involving proceedings under section 147 r.w.s. 144 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).

Heard both the parties. Case file perused.

2. This assessee’s appeal raises the following substantive grounds:

1. Order of the Ld. CIT(A) is bad in law and against the facts of the case and in upholding the order of L.d. AO passed u/s 144/147 on 10-12-

2019.

2. The Ld. CIT(A) is totally unjustified in upholding the order of Ld. AO who has assessed the income at Rs.