IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH, AMRITSAR.

BEFORE SH. UDAYAN DASGUPTA, JUDICIAL MEMBER AND SH. KRINWANT SAHAY, ACCOUNTANT MEMBER (Physical Hearing)

I.T.A. No. 237/Asr/2023 Assessment Year: 2012-13 Nasa Agro Industries Private Vs. Dy. CIT-Circle-II, Ltd. Village Painchawali Distt. Bathinda.

Fazilka, Punjab.

[PAN:-AAACN7050J]

(Appellant) (Respondent)

Appellant by Sh. Y. K. Sud, CA.

Respondent by Sh. Charan Dass, Sr. DR Date of Hearing 19.02.2026 Date of Pronouncement 28.04.2026

ORDER

Per: Udayan Dasgupta, J.M.:

This appeal has been filed by the assessee against the order of the Ld.

Commissioner of Income Tax (Appeals)-NFAC dated 28/06/2023, for the Assessment Year 2012-13, which has arisen out of the order of the AO passed u/s 143(3) / 147 of the Act, 1961, dated 29/12/2018.

2. The grounds taken by the assesee in revised form 36, are as follows:

“1. That learned CIT(A) has arbitrarily upheld initiation of reassessment proceedings on the basis of recorded reasons of judicial precedent which did not exist at the time of initiation and thus proceedings are illegal and void ab initio

2. That learned CIT(A) has wrongly upheld invocation of section

50C to sale of leasehold rights in