IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘G’: NEW DELHI BEFORE SHRI C.N. PRASAD, JUDICIAL MEMBER AND SHRI M. BALAGANESH, ACCOUNTANT MEMBER ITA No.5661& 4857/Del/2024 [Assessment Year: 2017-18]

Shivaaditiya Jems and Vs. ITO Jewellery Pvt. Ltd. Ward- 2 (1) A-197, Ramganga Vihar, Moradabad Phase-1, Kanth Road, MDA Moradabad PAN No.AASCS6911R Appellant Respondent Assessee by Sh. Sourabh Rohtagi, CA Sh. Rajat Mittal, CA Revenue by Sh. Mahesh Kumar, CIT DR Sh. Sahil Kumar Bansal, Sr. DR Date of Hearing 27.10.2025 Date of Pronouncement 31.12.2025

ORDER

PER C.N. PRASAD, JM, These two appeals are filed by the assessee and revenue against the orders of the Ld.Commissioner of Income Tax (Appeals)/NFAC, Delhi [herein after referred as “CIT(A)”] for the dated 23.08.2024 for the A.Y. 2017-18.

2. The assessee in its appeal challenged reopening of assessment and the validity of notice issued u/s.148A of the Act and the revenue challenge the order of the CIT(A) in deleting the addition made in respect of the addition made u/s.69C of the Act. Since the assessee has challenged from validity of notice issued u/s.148 of the Act and the jurisdiction of AO in framing the assessment, first we take