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2026 Supreme(Online)(ITAT) 7334

INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
C. V. Bhadang, President, Prabhash Shankar, Accountant Member
Sahyadri Erectors Private Limited – Appellant
Versus
Income Tax Officer, Ward 13(2)(1) – Respondent


Advocates:
For the Appellants/Petitioners:Shri Mayank Patwari, Advocate & Shri Rishav Patawari, CA
For the Respondents: Shri Arun Kanti Datta,(CIT DR)

Table of Content
1. ao added rs.195 cr loan u/s 68 doubting genuineness. (Para 2 , 3)
2. assessee argued procedural violation u/s 144b and merits. (Para 4)
3. cit(a) dismissed; assessee reiterated no scn issued. (Para 5 , 6 , 7)
4. s.144b mandatory; non-compliance renders order non est. (Para 8)
5. appeal allowed; de novo proceedings permitted. (Para 9 , 10)

आदेश/ORDER 

PER PRABHASH SHANKAR [A.M.] :-

The present appeal arising from the appellate order dated 11.10.2023 is filed by the assessee against the order passed by the Learned Commissioner of Income-tax (Appeals)/National Faceless Appeal Centre, Delhi [hereinafter referred to as “CIT(A)”] pertaining to assessment order passed u/s. 143(3) r.w.s. 144B of the Income-tax Act, 1961 [hereinafter referred to as “Act”] dated 23.09.2021 for the Assessment Year [A.Y.] 2018-19.

2. The grounds of appeal are as under:

1. On the facts and in the circumstances of the appellant’s case and in law, the Learned Commissioner of Income Tax (Appeal) erred in not quashing the assessment order passed by the AO u/s 143(3) r.w.s. 144B of the Income Tax Act, 1961.

2. On the facts and in the circumstances of the appellant’s case and in law, the Ld. Commissioner of

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