ORDER

PER PRASHANT MAHARISHI, VICE – PRESIDENT

i. This appeal has been filed by the Deputy Commissioner of Income Tax, Circle 3(1)(9), Bangalore (the learned Assessing Officer) in the matter of G Corp Private Limited (the Assessee) for Assessment Year 2014–15. The appeal challenges the appellate order issued by The Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (the learned CIT(A)), dated 14 February 2025, whereby the assessee’s appeal against the assessment order dated 29 December 2019, passed under section 143(3) read with section 263 of The Income Tax Act, 1961, was allowed. The CIT(A) held that no notice under section 143(2) was issued by the learned Assessing Officer when passing the assessment order under section 143(3) read with section 263, pursuant to the revisionary order under section 263 of the Act, which is considered mandatory. This decision was based on the judgment of the Honourable Supreme Court of India in Hotel Blue Moon (TS-113-SC- 2010-O), resulting in the quashing of the assessment order.

ii. The learned assessing officer has raised following grounds of appeal:–

1. The learned CIT(A) has erred in holding that the assessment order pass