आदशे/ORDER

PER ABY T. VARKEY, JM:

This is an appeal preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeal), (hereinafter referred to as ‘Ld.CIT(A)‘), Delhi, dated 12.09.2025 for the Assessment Year (hereinafter referred to as ‘AY’) 2018-19.

2. The assessee is an individual and didn’t file the return of income (RoI) for A.Y 2018-19, despite the assessee has time-deposit other than interest on securities of ₹20 lakhs and that she had sold immovable property at ₹1.80 Crs. Based on this facts/information, the A.O issued notice u/s. 148A(b) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) proposing to reopen; and subsequently the AO passed an order u/s.148A(d) of the Act on 13.04.2022 and issued notice u/s. 148 of the Act on the same date, conveying his desire to reopen the assessment for AY 2018-19. Pursuant to which,