IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’: NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER and SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER (Assessment Year: 2015-16)

G.S. Automobiles Private Limited, vs. DCIT, Central Circle 6, B – 26, Okhla Industrial Area, Phase II, Delhi.

Delhi – 110 020.

(PAN : AADCG1150B)

(APPELLANT) (RESPONDENT)

ASSESSEE BY : Shri Neeraj Mangla, CA REVENUE BY : Shri Jitender Singh, CIT DR Date of Hearing : 19.11.2025 Date of Order : 30.12.2025

O R D E R

PER S. RIFAUR RAHMAN, ACCOUNTANT MEMBER :

1. The assessee has filed appeal against the order of the Learned Commissioner of Income Tax (Appeals), Delhi – 24 [“Ld. CIT(A)”, for short] dated 19.06.2025 for the Assessment Year 2015-16 raising following grounds of appeal :-

“1. That the orders passed by Ld. AO u/s 153C of the Act as well as appellate order passed by Ld. CIT(A) are bad in law and are passed in contravention of prevailing law as well as facts of the case, therefore liable to be annulled.

2. That assumption of jurisdiction of Ld. AO in consequence of order passed by Ld. PCIT u/s 127(3) of the Act of the Act is illegal and not tenable under the law because of said order being mechanical and