IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘E’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No. 7833/Del/2025 Assessment Year: 2015-16 M/s Peakwood Reality Pvt. Vs. Assistant Commissioner of Ltd. Income Tax Shop No. 6, Jagdamba Central Circle-II Palace, Near Gurgaon New CGO Compled, NH- IV, Dreamz Mall, Old Railway NIT Faridabad- 121001 Road, Gurugram- 122001 PAN: AACCE1245J (Appellant) (Respondent)

Assessee by Sh. S.S. Nager, CA Sh. Harsh Raghav, Adv.

Department by Ms. Amisha S. Gupt, CIT DR Date of hearing 21.05.2026 Date of pronouncement 21.05.2026 ORDER PER SATBEER SINGH GODARA, JM This assessee’s appeal for assessment year 2015-16, arises against the Commissioner of Income Tax (Appeals)-3 [in short, the “CIT(A)”], Gurgaon’s DIN and order no. 10669/CIT(A)/GGN- 3/2019-20, dated 17.09.2025 involving proceedings under section 147 r.w.s. 143(3) of the Income-tax Act, 1961; hereinafter referred to as ‘the Act’.

Heard both the parties. Case file perused.

2. Coming to the first and foremost issue of validity of the impugned reopening itself between the parties, we notice at the outset that the learned Assessing Officer