“Income-tax Officer”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(25) / Section 1175,006 judgments

The decision most relied on for Income-tax Officer is CIT v. Max India Ltd. (295 ITR 282), cited in 1,162 judgments on BharatTax.

Leading authorities on Income-tax Officer

CIT v. Max India Ltd.

295 ITR 282 · 2007 · Supreme Court

1,162

citing judgments

Under Section 263, an assessment order is not erroneous and prejudicial to the interest of the revenue merely because the Principal Commissioner disagrees with the Assessing Officer's (AO) view, particularly if the AO has adopted one of two permissible views in law, unless that view is completely unsustainable. If due inquiries were made, the AO's order does not become erroneous solely because the fact of inquiries was not recorded.

Dhakeshwari Cotton Mills Ltd. v. CIT

26 ITR 775 · 1954 · Supreme Court

1,061

citing judgments

Corroborative evidence is essential to support evidence found on third-party premises, and an assessment cannot be based on suspicion, surmises, or conjecture.

Kale Khan Mohammad Hanif v. CIT

50 ITR 1 · 1963 · Supreme Court

581

citing judgments

The assessee bears the onus of proving the source and nature of any sum of money or receipt found to have been received by them. If the assessee fails to satisfactorily explain the receipt, the Income-tax Officer is entitled to treat it as taxable income.

Union of India v. Ashish Agarwal

444 ITR 1 · 2022 · Supreme Court

524

citing judgments

Notices issued under the unamended Section 148 of the Income-tax Act between April 1, 2021, and May 4, 2022, must be treated as notices issued under the new Section 148A(b) of the amended law. This requires the Assessing Officer to follow the procedure prescribed under the amended reassessment provisions, including issuing an order under Section 148A(d) before a fresh notice under Section 148.

CIT v. Kanpur Coal Syndicate

53 ITR 225 · 1964 · Supreme Court

359

citing judgments

The Commissioner (Appeals) holds plenary powers when disposing of an appeal, with their scope being coterminous with the Assessing Officer. This allows the CIT(A) to exercise all powers of the AO, including admitting additional evidence and redetermining income.

222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.

384 ITR 147 · 2016 · High Court

274

citing judgments

An assessment can be reopened if there is tangible material indicating escapement of income, demonstrating a live link between the material and the reasons recorded for reopening. The Assessing Officer must apply their mind to the material facts, and the sanction under section 151 should not be based on borrowed satisfaction.

Paul Mathews & Sons. v. CIT

263 ITR 101 · 2003 · High Court

266

citing judgments

A statement recorded under Section 133A of the Income-tax Act has no evidentiary value because Section 133A does not empower an Income-tax Officer to examine any person on oath.

Navnitlal C. Javeri v. K.K. Sen

56 ITR 198 · 1965 · Supreme Court

230

citing judgments

The Supreme Court holds that circulars issued by the Central Board of Direct Taxes (CBDT) are binding on all officers and persons employed in the execution of the Income-tax Act. These circulars are binding even if they deviate from the provisions of the Act, particularly when issued to relieve hardships.

Judgments citing Income-tax Officer

Email Pharmaceuical Industries Pvt Ltd, Mumbai vs. PCIT-4, Mumbai

In the result, the appeal filed by the assessee is partly allowed

ITA 2079/MUM/2025[2020-21]Status: DisposedITAT Mumbai19 Sept 2025AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarm/S Emil Pharmaceutical V/S. Principal Commissioner Of Industries Pvt. Ltd. बनाम Income Tax-4 101, Mangalam, Kulupwadi Room No. 629, Aayakar Road, Borivali East, Mumbai Bhawan, Maharishi Karve –400101, Maharashtra Road, Mumbai–400020, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaace0922A Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Anil Thakrar, CA (Virtually appeared)For Respondent: Shri Hemanshu Joshi, (Sr. DR)

Section 115BSection 142(1)Section 143(3)Section 263Section 80G

aforesaid definitions it is clear that an order cannot be termed as erroneous unless it is not in accordance with law. If an Income-tax Officer acting in accordance with law makes a certain assessment, the same cannot be branded as erroneous by the Commissioner simply because, according ... been written more elaborately. This section does not visualize a case of substitution of the judgment of the Commissioner for that of the Income-tax Officer, who passed the order unless the decisions is held to be erroneous. Cases may be visualized where the Income-tax Officer while making

Pushpanjali Constructions Private Limited, Pushpanjali Palace, Dehli Gate, Agra vs. DCIT, Cen Cir Ghaziabad

In the result appeal filed by the assessee is partly allowed

ITA 1001/DEL/2025[2012-13]Status: DisposedITAT Delhi19 Sept 2025AY 2012-13

Bench: Shris.Rifaur Rahman & Shri Sudhir Kumar

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Ms. Amisha S. Gupt, CITDR

Section 143(3)Section 153ASection 153CSection 153DSection 69C

Para 17) c). PCIT (Central) vs. DSG Papers (P.) Ltd as reported in [2024] 161 taxmann.com 586 (Punjab & Haryana) [09-11-2023] d). — Income-tax Officer, VII(2), Ludhiana vs. Dr. R.L. Narang as reported in [2008] 174 Taxman 96 (Chandigarh) e). ACIT vs. Ms. Katrina Rosemary Turcotte

Santosh Rani Legal Heir of Late Sh Parveen Kalyan, Kurukshetra vs. Income Tax Officer, Ward 1, Karnal

In the result, appeal of the assessee is allowed

ITA 4770/DEL/2024[2011-12]Status: DisposedITAT Delhi19 Sept 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2011-12] Santosh Rani Vs Ito, Legal Heir Of Late Shri Parveen Ward-1, Karnal, Kalyan, Krishna Nagar, Gamri, Haryana-132001. Thanesar, Distt.-Kurukshetra, Haryana-136118. Pan-Awhpr4944D Appellant Respondent Appellant By Shri Suresh K.Gupta, Ca Respondent By Shri Dheeraj Kumar Jaiswal, Sr.Dr Date Of Hearing 01.07.2025 Date Of Pronouncement 19.09.2025 Order

Section 144Section 147Section 148Section 151Section 250

this court as it suggests that the decision has been taken in a mechanical manner. Even if the reasoning set out by the Income-tax Officer was to be agreed upon, the least which is expected is that an appropriate endorsement is made in this behalf set-ting out brief ... case to issue notice under section 148. The important safeguards provided in sections 147 and 151 were lightly treated by the Income-tax Officer as well as by the Commissioner. Both of them appear to have taken the duty imposed on them under those provisions as of little importance. They

Usha Devi, Ghaziabad vs. ITO Ward 44(6), New Delhi

In the result, appeal of the assessee is partly allowed

ITA 1233/DEL/2024[2017-18]Status: DisposedITAT Delhi19 Sept 2025AY 2017-18

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh[Assessment Year: 2017-18] Usha Devi, Ito, 30B/78, West Punjabi Bagh, Ward-44(6), Delhi-110026, Delhi. Vs Delhi. Pan- Aafpa1096H Assessee Revenue

Section 142(1)Section 143(2)Section 143(3)Section 69A

utilized for some other purpose. In view of the aforesaid, we delete the addition of Rs. 7,22,000/- -Mrs. Pushpa Rai v. Income-tax Officer 7 [2024] 159 taxmann.com 1585 (Delhi - Trib.) (92-96) ITA No.- 1233/Del/2024 Usha Devi 7. From the above, it could be seen that

Suhir Finance and Chits Pvt. Ltd., New Delhi vs. ITO Ward-24(2), New Delhi

Accordingly, the appeal filed by the assessee is allowed

ITA 8767/DEL/2019[2012-13]Status: DisposedITAT Delhi19 Sept 2025AY 2012-13

Bench: the Assessing Officer but the Assessing Officer has not disposed of the above objections. Further he submitted that assessee has raised submissions before the ld. CIT (A) and ld. CIT (A) has not appreciated the submissions of the assessee and dismissed the grounds raised by the assessee.

For Appellant: Shri Vikash Jain, AdvocateFor Respondent: Shri Sahil Kumar Bansal, Sr. DR

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 292B

returned back as undelivered. This assertion is backed by the observations of the Hon'ble Pune Tribunal in Anil Kisanlal Marda v. Income-tax Officer, Ward-3(1), Pune. 2.2 It is submitted that in the above-mentioned case law the court clearly held that once notice remains unserved

ITO, Ward- 24(3), New Delhi vs. Suhir Finance and Chits Pvt. Ltd., New Delhi

Accordingly, the appeal filed by the assessee is allowed

ITA 8656/DEL/2019[2012-13]Status: DisposedITAT Delhi19 Sept 2025AY 2012-13

Bench: SHRI MAHAVIR SINGH, VICE PRESDIENT, SHRI S. RIFAUR RAHMAN (Accountant Member)

For Appellant: Shri Vikash Jain, AdvocateFor Respondent: Shri Sahil Kumar Bansal, Sr. DR

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 292B

Meena Swarup, New Delhi vs. DCIT Circle-3(1)(2), New Delhi

In the result, appeal of the assessee is allowed

ITA 2050/DEL/2019[2014-15]Status: DisposedITAT Delhi19 Sept 2025AY 2014-15

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2014-15] Mrs. Meena Swarup, Vs Dcit, 397, Mandakini Enclave, Circle-3(1)(2), New Delhi-110019. Intl. Tax., Pan-Amrps5792E New Delhi. Appellant Respondent Appellant By Shri R.S.Ahuja, Ca & Shri P.S.Sodhi, Adv. Respondent By Shri Dheeraj Kumar Jain, Sr.Dr Date Of Hearing 01.07.2025 Date Of Pronouncement 19.09.2025 Order Per Manish Agarwal, Am :

Section 10(38)Section 143(2)Section 143(3)Section 250Section 68

said provision defines 'assessing officer' to mean the Assistant Commissioner or Deputy Commissioner or Assistant Director or Deputy Director or the Income-tax Officer, who is vested with the relevant jurisdiction by virtue of directions or orders issued under sub-section (1) or sub-section (2) of section

Arun Duggal, Faridabad vs. DCIT, Central Circle- 1, Faridabad

In the result, appeal of the assessee is partly allowed

ITA 3075/DEL/2018[2009-10]Status: DisposedITAT Delhi19 Sept 2025AY 2009-10

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2009-10] Arun Duggal, Vs Dcit, 3E-42, Nit, Faridabad, Central Circle-1, Haryana-121001. Faridabad. Pan-Agupd5708Q Appellant Respondent Appellant By Dr. Kapil Goel, Adv. Respondent By Shri Pravin Rawal, Cit Dr Date Of Hearing 26.06.2025 Date Of Pronouncement 19.09.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 26.02.2018 Passed By Ld. Commissioner Of Income Tax (A)-3, Gurgaon [“Ld.Cit(A)”] In Appeal No.617/Cit(A)-3/Ggn/2016-17 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 23.12.2016 Passed U/S 147 R.W.S. 143(3) Of The Act Pertaining To Assessment Year 2009-10. 2. Brief Facts Of The Case Are That The Appeal Of The Assessee Was Heard By The Co-Ordinate “E” Bench Of The Tribunal & Was Decided In Terms Of Order Dated 01.04.2022 Wherein Co-Ordinate Bench Has Dismissed The Appeal Of The Assessee. Thereafter, Assessee Filed Miscellaneous Application (M.A.) Bearing No.100/Del/2022 U/S 254(2) Of The Act. The Co-Ordinate Bench Vide Its Order Dated 09.04.2025 Has Decided The M.A. Filed By Assessee Wherein Order Of Co-Ordinate Bench Dated 04.01.2022 Is Recalled For The Limited Purposes Of Adjudication Of Three Grounds Of Appeal Taken In The Original Form 36. These Grounds Of Appeal Are Bearing Nos.1.2, 1.8 & 5. The Relevant Observations Of The Co-Ordinate Bench In Para 16 Of The Order Of Ma Are As Under:-

Section 147Section 151Section 250Section 254(2)Section 68

Sh. Hari Prakash Gupta, Jaipur vs. ITO, Ward-1(2), Jaipur

The appeal stands allowed

ITA 772/JPR/2025[2010-11]Status: DisposedITAT Jaipur18 Sept 2025AY 2010-11

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P. C. Parwal, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT

Section 144Section 147Section 148Section 271(1)(c)Section 37(1)Section 44A

notice required to be issued under the said section has not been issued against the assessees contemplated therein. In the present case the Income-tax Officer has purported to act under section 34(1)(a) against the three firms. The said sub-section provides, inter alia, that 'if the Income ... validity of any reassessment made under section 34; and if a valid notice is not issued as required, proceedings taken by the Income-tax Officer in pursuance of an invalid notice and consequent orders of reas-sessment passed by him would be void and inoperative. In our opinion, this contention

Sh. Hari Prakash Gupta, Jaipur vs. ITO, Ward-1(2), Jaipur

The appeal stands allowed

ITA 771/JPR/2025[2010-11]Status: DisposedITAT Jaipur18 Sept 2025AY 2010-11

For Appellant: Shri P. C. Parwal, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT

Section 144Section 147Section 148Section 271(1)(c)Section 37(1)Section 44A

Vivek Tracom Pvt. Ltd., Kolkata vs. I.T.O., Ward - 5(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2522/KOL/2024[2017-2018]Status: DisposedITAT Kolkata18 Sept 2025AY 2017-2018

Bench: Shri Rajesh Kumar, Am & Shrisonjoy Sarma, Jm

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Pankaj Pandey, DR

Section 143(2)

accruing on doubtful debts is credited to a suspense account, It need not be included in the assessee's taxable income, provided the Income-tax Officer is satisfied that recovery is practically improbable. Twenty-six years later, on June 20, 1978, in view of the judgment of the Kerala High

The Chennai Co-Op. Societies Employees Co-Op. and Society Ltd., Chennai vs. PCIT-8, Chennai

In the result, appeal filed by the assessee is allowed

ITA 1157/CHNY/2025[2018-19]Status: DisposedITAT Chennai18 Sept 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.B. Suresh, CAFor Respondent: Mr.Bipin C.N., CIT

Section 139(1)Section 144BSection 148Section 151ASection 263Section 80ASection 80P

jurisdictional High Court & other Hon’ble High Courts as noted infra:- Sl.No. Date Citation 1 24.06.2025 Mark Studio India (P.) Ltd. v. Income-tax Officer - High Court of Madras [DB] - WA No. 781 OF 2025, order dated 24.06.2025 2 14.09.2023 Kankanala Ravindra Reddy v. Income-tax Officer High Court ... Narayan Sah v. Union of India - High Court of Gauhati 163 taxmann.com 478 5 02.07.2024 Sushila Sureshbabu Malge v. Income-tax Officer - High Court of Bombay - 468 ITR 624 6 19.07.2024 Jatinder Singh Bhangu v. Union of India High Court of Punjab & Haryana - 466 ITR 474 7 24.07.2024 Sri Venkataramana

Anandmangal Investment and Finance Private Limited, Mumbai vs. Income Tax Officer, Aaykar Bhavan Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 4166/MUM/2025[2012-13]Status: DisposedITAT Mumbai18 Sept 2025AY 2012-13

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Shri Ajay Singh & Shri Akshay PawarFor Respondent: Shri Surendra Mohan (SR DR)

Section 142(1)Section 143(3)Section 148Section 250

MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE, JUDICIAL MEMBER I.T.A No.4166/Mum/2025 (Assessment Year: 2012-13) Anandmangal Investment & vs Income-tax Officer, W-12(1)(1), Finance Pvt Ltd, Mumbai 129, 1st Floor, Aayakar Bhavan, M.K. 201, Hemlok Apartment, 87, Kilachand Path, Kandivali, Mumbai Road, Mumbai ... shot, ‘the Act) for the Assessment Year 2012- 13, date of order 19/01/2024. The impugned order emanated from the order of the Learned Income-tax Officer, Ward 12(1)(1), Mumbai (in short, ‘the Ld.AO’) passed u/s 143(3) r.w.s. 147 of the Act, date of order 16/12/2019. 2 Anandmangal

Advantage India, New Delhi vs. Pr.CIT (Central)-II, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 634/DEL/2019[-]Status: DisposedITAT Delhi18 Sept 2025

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Sanjay Mehra, FCAFor Respondent: Shri Javed Akhtar, CIT [DR]

Section 127Section 127(2)Section 12ASection 13(1)(c)

clause (7A) of section 2 of the said Act, to the Deputy Commissioner of Income-tax or Assistant Commissioner of Income-tax or Income-tax Officer who are subordinate to them. 2. This notification shall come into force with effect from the 15th day of November, 2014 SCHEDULE

Radheshyam Paper Mills Private Limited, Lilapar Road, Lilapar vs. PCIT-Rajkot-1, Income Taxdepartment, Office of the Principal Commissioner of Income Tax, Aaykar Bhavan Ring Road Race Course Rajkot

In the result, appeal OF the assessee is allowed

ITA 243/RJT/2024[2019-20]Status: DisposedITAT Rajkot17 Sept 2025AY 2019-20

Bench: DR. ARJUN LAL SAINI (Accountant Member), SHRI DINESH MOHAN SINHA (Judicial Member)

For Appellant: Shri P.J. Raiyani, Ld.A.RFor Respondent: Smt. Pallavi, Ld.CIT-D.R

Section 115BSection 143(3)Section 263Section 56Section 69Section 69B

consequence of an order of the Assessing Officer, cannot be treated as prejudicial to the interests of the Revenue, for example, when an Income-tax Officer adopted one of the courses permissible in law and it has resulted in loss of revenue, or where two views are possible ... Income-tax Officer has taken one view with which the Commissioner does not agree, it cannot be treated as an erroneous order prejudicial to the ITA.243/Rjt/2024/AY.2019-20 Radheshyam Paper Mills Pvt. Ltd. interests of the Revenue unless the view taken by the Income-tax Officer is unsustainable

Mcm Developers, Aurangabad vs. DCIT. Central Circle-1, Aurangabad

In the result, the appeal filed by the assessee is allowed

ITA 362/PUN/2025[2018-2019]Status: DisposedITAT Pune17 Sept 2025AY 2018-2019

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Pramod ShingteFor Respondent: Shri Amol Khairnar

Section 143(3)Section 153ASection 153CSection 154Section 269SSection 270ASection 271DSection 40A(3)

passed by Hon’ble Supreme Court in the case of CIT vs. Hero Cycles P. Ltd. (1997) 94 Taxman 271 (SC) & T.S. Balaram, Income-tax Officer vs. Volkart Brothers (1971) 82 ITR 50 (SC) wherein Hon’ble Supreme Court held that “a mistake apparent on the record” must ... original assessment order & therefore in the light of Judgements passed by Hon’ble Supreme court in the case of T.S. Balaram, Income-tax Officer vs. Volkart Brothers (1971) 82 ITR 50 (SC), rectification u/s 154 of the IT Act is not permissible. Hon’ble Supreme court in the above case

Ashwani Kumar, Sonipat vs. Inccome Tax Officer, Sonipat

Appeal is allowed for statistical purposes

ITA 95/DEL/2025[2012-13]Status: DisposedITAT Delhi17 Sept 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2012-13 Ashwani Kumar, Vs Income-Tax Officer, Village Rathdhana, Ward-1, Sonipat Sonepat. Haryana – 131 001. Pan: Bgjpk9766R (Appellant) (Respondent) Assessee By : None Revenue By : Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing : 02.09.2025 Date Of Pronouncement : 17.09.2025

For Appellant: NoneFor Respondent: Shri Ajay Kumar Arora, Sr. DR

Section 143(3)Section 271(1)(b)Section 271F

DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI ANUBHAV SHARMA, JUDICIAL MEMBER Assessment Year: 2012-13 Ashwani Kumar, Vs Income-tax Officer, Village Rathdhana, Ward-1, Sonipat Sonepat. Haryana – 131 001. PAN: BGJPK9766R (Appellant) (Respondent) Assessee by : None Revenue by : Shri Ajay Kumar Arora, Sr. DR Date

Skc Gyanyog Events Association, Delhi vs. Commissioner of Income Tax (Exemption), Delhi

ITA 2255/DEL/2025[2025-26]Status: DisposedITAT Delhi17 Sept 2025AY 2025-26

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2025-26 Skc Gyanyog Events Vs Income-Tax Officer, Association, Ward-1, A-247, Ff Meera Bagh, Sonepat. Paschim Vihar, Near St Mark School, Sunder Vihar, Delhi – 110 087. Pan: Ablcs0641L (Appellant) (Respondent) Assessee By : Shri N.K. Chand, Advocate & Shri Manish Upneja, Ca Revenue By : Shri Jitender Singh, Sr. Dr Date Of Hearing : 02.09.2025 Date Of Pronouncement : 17.09.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Order Dated 21.06.2024 Of The Commissioner Of Income-Tax (Exemption), Delhi (Hereinafter Referred To As The ‘Ld. Cit(E)’ For Short) U/S 12Ab(1)(B)(Iii)(B) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) By The Ito, Rejecting The Application Filed In Form 10Ab For Registration U/S 12A(1)(Ac)(Iii) Of The Act.

For Appellant: Shri N.K. Chand, Advocate &For Respondent: Shri Jitender Singh, Sr. DR

Section 12ASection 12A(1)(ac)Section 8

DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI ANUBHAV SHARMA, JUDICIAL MEMBER Assessment Year: 2025-26 SKC Gyanyog Events Vs Income-tax Officer, Association, Ward-1, A-247, FF meera Bagh, Sonepat. Paschim Vihar, Near ST Mark School, Sunder Vihar, Delhi – 110 087. PAN: ABLCS0641L (Appellant) (Respondent) Assessee

M/S. Taneja Developers & Infrastructure (Panipat) Ltd., New Delhi vs. DCIT, New Delhi

ITA 2409/DEL/2015[2009-10]Status: DisposedITAT Delhi17 Sept 2025AY 2009-10

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay

For Respondent: Shri Salil Agarwal, Sr. Advocate &

Section 143(3)Section 153D

issue before Hon'ble Bench. the instant case are distinguishable. Reliance is placed in the case of Home Finders Housing Ltd. v Income-tax Officer Ward 2(3), Chennai [2018] 93 taxmann.com 371 (Madras) wherein it was held that in case an order is passed without following a prescribed procedure

DCIT, New Delhi vs. M/S. Tdi Infrastructure Ltd., New Delhi

ITA 3953/DEL/2014[2009-10]Status: DisposedITAT Delhi17 Sept 2025AY 2009-10

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay

For Respondent: Shri Salil Agarwal, Sr. Advocate &

Section 143(3)Section 153D