IN THE INCOME TAX APPELLATE TRIBUNAL DELHI DELHI BENCH ‘C’: NEW DELHI BEFORE YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No. 4748/Del/2025 (A.Y 2023-24)

Ravi Chopra, Vs Income Tax Officer

9/54, Basement Ward 61(2)

Vikram Vihar, Lajpat Nagar-IV Delhi New Delhi-110024 PAN: AADPC9425E Appellant Respondent Assessee by Sh. Sandeep Sapra, Adv Revenue by Sh. Om Prakash, Sr. DR Date of Hearing 25/03/2026 Date of Pronouncement 15/05/2026 ORDER PER YOGESH KUMAR, U.S. JM:

The present appeal is filed by the Assessee against the order of Ld.

Commissioner of Income Tax (Appeals/ National Faceless Appeal Centre (‘Ld. CIT(A)/NFAC’ for short), New Delhi dated 25/09/2025 for the Assessment Year 2011-12.

2. The grounds of Appeal are as under:

“1. That the impugned assessment order dated 27/12/2018 for Assessment Year 2011-12 passed u/s 143(3)/147 of the Income Tax Act, 1961 ('Act' for short) deserves to be quashed/annulled because: a) Initiation of proceedings u/s 147/148 of the Act is bad in law.

b) There is no proper application of mind on the part of the A.O. so as to come to an independent satisfaction that he had reason to believe that income and escaped assessment.