O R D E R

PER M. BALAGANESH, A. M.:

1. The appeal in ITA No.597/AGR/2025 for AY 2019-20, arises out of the order of the ld National Faceless Appeal Centre, Delhi [hereinafter referred to as ‘ld. CIT(A)’, in short] dated 24.10.2025 against the order of assessment passed u/s 147 r.w.s 144B of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 17.02.2025 by KNP-W-(75)(1) (hereinafter referred to as ‘ld. AO’).

2. The assessee has raised the following grounds of appeal:-

“1. BECAUSE, the Ld. CIT(A) erred in upholding the reopening and the assessment u/s 147 r.w.s. 144B without examining whether the "reason to believe" recorded by the AO was based on tangible material or mere borrowed satisfaction from the DDIT(Inv.) report. The conclusion that the reopening was valid is perverse and contrary to settled law, causing grave prejudice to the appellant.

2. BECAUSE, the Ld. CIT(A) wrongly assumed that "no satisfactory explanation" or supporting evidence was filed, ignoring that confirmations, ITRs, balance sheets, and bank statements of all creditors were duly filed and remained unrebutted. This finding is perverse and contrary to the record, vitiating the order in toto.

3.