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IN THE INCOME TAX APPELLATE TRIBUNAL

“SMC” BENCH, DELHI

BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER

ITA No. 6968/DEL/2025 (AY: 2018-19)

(Physical hearing)

Infinite Expeditions Pvt. Ltd. Income Tax Officer, Ward 2(1)(1),

B.K. Complex, S-3, Opp. Krishna Vs Ghaziabad.

Kunj Colony, Tibra Road, Modinagar, Income Tax Building, CGO

Ghaziabad, Uttar Pradesh-201204 Complex-1, Purani Hapur Chungi,

[PAN: AAECI0872M] Ghaziabad, Uttar Pradesh-201002

Appellant / Assessee Respondent / Revenue

Assessee by Shri Lakshay Gupta, CA

Revenue by Shri Virendra Kumar Singh, Sr. DR

Date of institution of appeal 31.10.2025

Date of hearing 01.12.2025

Date of pronouncement 23.12.2025

Order under section 254(1) of Income Tax Act

PER PAWAN SINGH, JUDICIAL MEMBER;

1. This appeal by assessee is directed against the order of ld. CIT(A) dated

14.10.2025 for A.Y. 2018-19. The assessee has raised following grounds of

appeal:

(1) That impugned assessment proceeding-initiated u/s 147 of the Income Tax

Act, 1961 (hereinafter referred as the act) vide statutory notice dated

30.03.2022 issued u/s 148 of the act is non-est and void being said notice

has been issued in gross contravention of e-Assessment of Income

Escaping Assessment 1 Scheme, 2022 notified by Honourable CBDT u/s

151A of the act on 29.03.2022 vide CBDT Notification No. 18/2022 as the

authority prescribed and empowered to issue such statutory notice u/s 148

of the act lies with Faceless Assessing Officer and not with the

Jurisdictional Assessing Officer. As such, impugned assessment proceeding

deserves to be quashed at the threshold.

ITA No. 6868/ Delhi /2025

Infinite Expeditions Pvt Ltd. (AY 2018-19)

(2) That the Ld. Income Tax Officer, Ward 2(1)(1), Ghaziabad (hereinafter

referred as Ld. JAO) had erred in law and facts of the matter by initiating

proceeding u/s 148A of the act merely on the basis of certain information

flagged on insight portal to conduct further investigation to verify the

authenticity and veracity of said information without even confronting the

material available on record. Thereby, Ld. JAO had contravened the

principle of natural justice and consequently, said enquiry proceeding and

subsequent assessment proceeding deserves to be quashed.

(3) That the Ld. CIT(A) has erred in law and facts of the matter while

sustaining the Assessment Order without appreciating that the additions

have been made without providing adequate opportunity of being heard to

the Appellant. As such, the Assessment Order passed in violation of the

principle of natural justice is illegal and may please be quashed.

(4) That the Ld. CIT(A) had erred in law and facts of the matter by confirming

the additions of Rs. 21,39,398/- made u/s 68 of the act on account of

alleged unexplained cash credit found in the bank statements of appellant

without appreciating the fact that said credits were duly recorded in books

of accounts of the appellant and were appropriately reported in Audited

Financial Statements prepared for the period under consideration. As such,

the addition of Rs. 21,39,398/- is bad in law and may please be deleted.

(5) That the Ld. CIT(A) had erred in law and facts of the matter by confirming

the additions of Rs. 21,39,398/- made u/s 68 of the act on account of

alleged unexplained cash credit found in the bank statements of appellant

merely under the apprehension that the appellant company was not found

at the registered address during the course of inspection conducted by the

office of Investigation Wing of the Income Tax Department without

appreciating the fact that the appellant had shifted its business premises

from address, WHARE inspection was conducted and details of subsequent

address were duly reported in ITRs filed for AY's subsequent to such

shifting. Thereby, additions of Rs. 21,39,398/- made solely on the basis of

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Infinite Expeditions Pvt Ltd. (AY 2018-19)

inappropriate apprehension drawn by another statutory authority without

proper application of mind deserves to be deleted.

2. Brief facts of the c