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. BECAUSE, the Ld. CIT(A) erred in sustaining the AO's reliance on the DDIT(Inv.) report alleging M/s Oasis Tradewings (P) Ltd. to be non-existent without verifying its changed registered address as per MCA and Income-tax records. The conclusion that it was a "shell company" is based on incorrect facts, unverified assumptions, and denial of cross-examination thereby violating principles of natural justice.

4. BECAUSE, the Ld. CIT(A) erred in affirming the AO's presumption that the total bank credits of Rs. 2.09 crore constituted "turnover." The AO's method of computing income by applying N.P rate of 94% on such bank credits is patently perverse and unsupported by any accounting or legal principle, resulting in an illogical and inflated addition.

5. BECAUSE, the Ld. CIT(A) has mechanically reproduced the findings of the AO and Investigation Wing without independent appraisal or reasoning. The appellate order shows non-application of mind and absence of judicial consideration expected from a quasi-judicial authority.

6. BECAUSE, the Ld. CIT(A) erred in upholding an addition based on third-party investigation reports without granting opportunity to cross-examine or confront the material relied upon. The order suffers from breach of natural justice and is liable to be set aside on this ground alone.

7. BECAUSE, the Ld. CIT(A) erred in ignoring the appellant's submission that the credits primarily represented legitimate receipts and settlements from MCX commodity trading activities and inter-account transfers from her father, duly supported by broker statements and bank trails.

8. BECAUSE, the Ld. CIT(A) failed to appreciate that the AO's estimation of Net Profit at the rate of 94% is irrational, excessive, and without any precedent or comparative benchmark. The finding that such profit rate represents "undisclosed business income" is arbitrary and devoid of evidentiary support.

9. The impugned appellate order suffers from non-application of mind, being a mere reproduction of the assessment order without adjudication of each ground or discussion on the evidence placed. Such an order is void ab initio and contrary to section 250(6) of the Act.”

3. We have heard the rival submissions and perused the material available on record. The ground No. 1 raised by the assessee is challenging the validity of reopening of assessment u/s 147 of the Act. No arguments were advanced in that regard at the time of hearing today. Hence, the same is hereby dismissed as not pressed.

4. The assessee is an individual deriving income from partnership firm business under the name and style M/s. Mobile World and MCX Trading Activities in her name. The return of income for AY 2019-20 was filed by the assessee on 20.07.2019 declaring total income of Rs. 10,63,460/-. The case of the as