O R D E R

PER SANDEEP SINGH KARHAIL, J.M.

The assessee has filed the present appeal against the impugned order dated 10/10/2025, passed under section 250 of the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, [“learned CIT(A)”], for the assessment year 2015-16.

2. The present appeal is delayed by 56 days. Along with the appeal, the assessee has filed an affidavit seeking condonation of the delay. Having perused the affidavit, which forms part of the record, we are of the considered view that there was sufficient cause which prevented the assessee from filing the present appeal within the prescribed limitation period. Accordingly, we condone the delay and proceed to decide the appeal.

3. In this appeal, the assessee has raised the following grounds: -

“1. On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in confirming reassessment proceedings u/s 148 of the Income Tax Act, 1961 which is bad in law and required to be quashed.

2. On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in confirming the action of Ld. AO in initiating reassessment proceeding under section 148 in violation of provision of section149 of Income Tax Act, 1961 as the proceeding for A.Y. 2015-16 is time barred.

3. On the facts and circumstances of the case and in law, the Ld. CIT(A) failed to appreciate the facts that the permission obtained under section 151 of the Act, is not in accordance with the law

4. On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in confirming the action of Ld. AO in in issuing notice under section 148 of Income Tax Act, 1961 without mentioning the DIN on notice itself which is violation of CBDT Circular No 19 of 2019 dated 14.08.2019.

5. On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in confirming the action of Ld. AO in making addition of Rs. 2,59,67,232 as unexplained cash credits under section 68 of Income Tax Act, 1961.

6. Without Prejudice to Ground No 5, On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in confirming the action of Ld. AO in making addition of Rs. 2,06,00,000/- under section 68 of Income Tax Act, 1961 on account of alleged accommodation entry from Shripal Vora despite knowing of facts that the appellant has not made any such transaction with such Shripal Vora and when nothing is credited during the year, then the provision of section 68 of Income Tax Act, 1961 is not applicable.

7. Without Prejudice to Ground No 5, On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in confirming the action of Ld. AO in making addition of Rs. 25,97,961/- under section 68 of Income Tax Act, 1961 on account of alleged accommodation entry from Darshan Sadhani despite knowing of facts that the appellant has not made any such transaction with such Darshan Sadhani and when nothing is credited during the year, then the provision of section 68 of Income Tax Act, 1961 is not applicable.

8. Without Prejudice to Ground No 5, On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in confirming the action of Ld. AO in making addition of Rs. 27,69,271/- under section 68 of Income Tax Act, 1961 on account of alleged accommodation entry despite knowing of facts that such amount was repayment of loan in A.Y. 2016-17 for which the loan was obtained in earlier years and no loan was taken in relevant assessment year A.Y. 2015-16. Thus, when nothing is credited during the year, then the provision of section 68 of Income Tax Act, 1961 is not applicable

9. On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in confirming the action of Ld. AO in charging interest under section 234B of the Income Tax Act, 1961.

10. On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in confirming the action of Ld. AO in initiating penalty proceedings under section 271(1)