IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH “G’’ : NEW DELHI)

BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER ITA No. 5909/Del/2025 Asstt. Year : 2018-19 ACIT, CIRCLE 7(1), vs. DELHI CONTROL DEVICES New Delhi PRIVATE LIMITED, ROOM NO. 406, 4^TH FLOOR, K-185/2, BASEMENT SURYA C.R. BUILDING, PLAZA, I.P. ESTATE, NEW DELHI NEW FRIENDS COLONY, NEW DELHI – 110 065 (PAN: AAACD2208G)

(Appellant) (Respondent)

ASSESSEE by : None REVENUE by : Shri Manish Gupta, Sr. DR Date of Hearing 02.03.2026 Date of Pronouncement 02.03.2026

ORDER

PER MAHAVIR SINGH, VP:

This appeal has been filed by the Revenue against the order dated

24.7.2025 passed by the NFAC, Delhi in appeal no. NFAC/2017-18/10333954. Assessment was framed vide order dated 1.3.2024 passed u/s. 147 r.w.s. 144B of the Act relevant for the relevant assessment year 2018-19.

2. The revenue has raised the following grounds of appeal:

1. Whether Ld. CIT(A) has erred in misconstruing the nature and purpose of the reassessment proceedings initiated u/s. 147 of the Act. The reassessment was initiated well before the finalization of the Corporate Insolvency Resolution Process (CIRP), solely for the purpose of c