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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
Anubhav Sharma, Judicial Member, Manish Agarwal, Accountant Member
Dy. Commissioner of Income Tax, Central Circle-1, Ghaziabad – Appellant
Versus
Mango Infratech Solutions Income Tax, Pvt. Ltd. – Respondent
| Table of Content |
|---|
| 1. company converted to llp; reassessment on non-existent entity (Para 2 , 3) |
| 2. revenue challenges cit(a) deletion of unexplained investments (Para 4) |
| 3. assessee argues notice u/s 148 void ab initio on non-entity (Para 5 , 6) |
| 4. revenue supports ao; cit(a) quotes precedents on non-existent assessments (Para 7 , 8) |
| 5. notice u/s 148 invalid; reassessment quashed as nullity (Para 9 , 10 , 11 , 12) |
| 6. revenue appeal dismissed; other grounds not adjudicated (Para 13 , 14 , 15) |
ORDER
PER MANISH AGARWAL, AM,
This appeal is filed by the revenue against the order of the ld. Commissioner of Income Tax (Appeals)-3, Noida [“ld. CIT(A)”] dated 10/07/2025 in appeal No. CIT(A), Ghaziabad/11458/2019-20 for Assessment Year 2013-14, passed under section 250 of the Income Tax Act, 1961 (hereinafter referred as ‘the Act’) arising out of the reassessment order passed u/s 147 of the Act dt. 18.12.2019.
2. Brief facts of the case are that the assessee was originally incorporated as a private limited company in terms of Certificate of Incorporation dt. 25.05.2010 and later converted into Limited Liability Partnership (“LLP”) under the name & style as “Mango Infratech Solutions LLP” on 16.10.2017
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