BOP PRIVATE LIMITED,BABAR ROAD, WORLD TRADE CENTRE, CONNAUGHT PLACE vs. ITO DEL-C-(32)(2), DELHI

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “F”, NEW DELHI BEFORE SHRI VIMAL KUMAR, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No. 3852/Del/2026, A.Y. 2013-14 BOP Private Limited Vs. Income Tax Officer, 119, B-7, DEL-C-(32)(2), Lower Ground Floor, New Delhi Babar Road World Trade Centre, Connaught Place, New Delhi 110001, New Delhi �थायीलेखासं./जीआइआरसं./PAN/GIR No: AADCB2583M Appellant .. Respondent Appellant by : None Respondent by : Ms. Harpreet Kaur Hansra, Sr. DR Date of Hearing 22.07.2026 Date of Pronouncement 22.07.2026 O R D E R PER VIMAL KUMAR, JM:

Application for condonation of delay of 20 days in filing appeal and the appeal filed by the appellant/assessee is against order dated 16.01.2026 of the

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ld. Commissioner of Income Tax (Appeals)/NFAC, Delhi (hereinafter referred to as ‘the CIT(A)’) u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) arising out of assessment order dated 10.05.2023 of Ld. Assessing Officer / Assessment Unit (hereinafter referred to as ‘the AO’) u/s 147 r.w.s. 144 r.w.s. 144B of the Act for Assessment Year 2013-14.

“1. On the facts and in the circumstances of the case and in law, the reopening of assessment under section 147 read with section 148 is illegal, bad in law, and without jurisdiction, and the same deserves to be quashed. 2. reassessment proceedings have been initiated beyond the prescribed time limit On the facts and in the circumstances of the case and in law, the under the Act and are therefore void ab initio and liable to be quashed. 3. On the facts and in the circumstances of the case and in law, the sanction obtained under section 151 for reopening is mechanical and without application of mind, thereby rendering the reassessment proceedings invalid. 4. On the facts and in the circumstances of the case and in law, the reopening is based merely on borrowed satisfaction and general Information from the Investigation Wing without any independent application of mind by the Assessing officer, hence invalid in law. 5. On the facts and in the circumstances of the case and in law, the procedure prescribed under section 148A has not been properly followed, and adequated

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opportunity of being heard was not provided, making the proceedings bad in law. 6. On the facts and in the circumstances of the case and in law, the addition of Rs 31933919 under section 68 is arbitrary, unjustified, and without proper appreciation of facts and evidence. 7. On the facts and in the circumstances of the case and in law, the learned AO & CIT(A) have erred is not allowing the TDS credit of rs 133046960. 8. On the facts and in the circumstances of the case and in law, the addition has been made without providing adequate opportunity and without confronting the appellant with adverse material, thus violating principles of natural justice.] 9. On the facts and in the circumstances of the case and in law, that the addition has been made merely on suspicion, surmises, and conjectures without any cogent evidence, which is not sustainable in law. 10. On the facts and in the circumstances of the case and in law, that the appellant craves to add, amend, alter, or withdraw any ground of appeal at the time of hearing.” 4. Ld. Departmental Representative relied on impugned order.

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Order pronounced in the open court on 22.07.2026

Sd/- Sd/- (MANISH AGARWAL) (VIMAL KUMAR) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated:27.07.2026 Binita, Sr. PS Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT ASSISTANT REGISTRAR ITAT, NEW DELHI