“Section 143(3)”

Section References (mined)Section 143Section 143(3)45,044 judgments

The decision most relied on for Section 143(3) is National Thermal Power Co. Ltd. v. CIT (229 ITR 383), cited in 5,834 judgments on BharatTax.

Leading authorities on Section 143(3)

National Thermal Power Co. Ltd. v. CIT

229 ITR 383 · 1998 · Supreme Court

5,834

citing judgments

Appellate authorities can consider new claims and additional grounds if the relevant facts are already on record. The purpose of assessment is to correctly determine tax liability, allowing both parties to raise issues.

Collector, Land Acquisition v. Mst. Katiji

167 ITR 471 · 1987 · Supreme Court

3,926

citing judgments

Delay in filing appeals, when supported by sufficient or justifiable cause, should be condoned with a liberal approach to ensure substantial justice. This principle prioritizes the cause of justice over mere technicalities.

CIT v. Kabul Chawla

380 ITR 573 · 2016 · High Court

3,235

citing judgments

In a search assessment under Section 153A, additions can only be made for completed or non-abated assessment years if incriminating material relevant to those years is found during the search, although notice under Section 153A(1) is mandatorily issued for six assessment years preceding the search.

Malabar Industrial Co. Ltd. v. CIT

243 ITR 83 · 2000 · Supreme Court

2,943

citing judgments

For revision under Section 263, the Assessing Officer's order must be both erroneous and prejudicial to the interests of the revenue; if either condition is not met, the revisionary jurisdiction cannot be invoked. An order is not erroneous merely because the Assessing Officer did not record the details of enquiries conducted, provided due enquiries were made.

CIT v. Vegetable Products Ltd.

88 ITR 192 · 1973 · Supreme Court

2,664

citing judgments

When two equally plausible interpretations of a taxing provision are possible, or when conflicting views exist from non-jurisdictional High Courts, the interpretation that favors the assessee must be adopted.

CIT v. Manjunatha Cotton & Ginning Factory

359 ITR 565 · 2013 · High Court

2,590

citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify whether the penalty proceedings are initiated for concealment of income or for furnishing inaccurate particulars of income. This non-specification vitiates the penalty proceedings.

Pr. CIT v. Abhisar Buildwell (P.) Ltd.

149 Taxmann.com 399 · 2023 · Supreme Court

2,379

citing judgments

An assessment under section 153A is without jurisdiction if there is an absence of incriminating material for an unabated assessment year.

CIT v. Multiplan India Ltd.

38 ITD 320 · 1991 · ITAT

2,267

citing judgments

An appeal before the Income Tax Appellate Tribunal can be dismissed for non-prosecution or treated as unadmitted when the appellant fails to appear, cooperate, or show diligence, in accordance with Rule 19(2) of the Income-tax (Appellate Tribunal) Rules. The law aids the vigilant, not those who sleep on their rights.

Judgments citing Section 143(3)

Repro India Limited, Mumbai vs. Assistant Commissioner of Income Tax, Mumbai

The appeal is allowed for statistical purposes

ITA 7605/MUM/2025[2022-23]Status: DisposedITAT Mumbai09 Feb 2026AY 2022-23

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarrepro India Limited Acit Circle 11Th Floor, B Wing, Sun 8(1)(1), Paradise Business Plaza, Vs. Aayakar Bhavan, Senapati Bapat Marg, Mumbai-400 020 Lower Parel, Mumbai – 400 013 Pan/Gir No. Aaacr0379J (Applicant) (Respondent) Assessee By Shri Vijay Mehta, Ld. Ar Revenue By Shri Umashankar Prasad, Ld. Dr Date Of Hearing 04.02.2026 Date Of Pronouncement 09.02.2026

Section 143(3)Section 144BSection 250

Assessment 2 Repro India Limited Year 2022–23, arising out of the assessment order passed by the Assessing Officer under section 143(3) read with section 144B of the Act, dated 27.03.2024. Facts of the Case 2. For the Assessment Year 2022–23, the assessee filed its original return ... worked out. Penalty proceedings under section 270A of the Act were initiated for alleged under-reporting of income. The assessment was completed under section 143(3) read with section 144B of the Act, determining total loss at Rs. 40,37,373/- as against loss

The Sri Hari Trust, Mumbai vs. Assistant Commissioner of Income Tax, Circle 21(3) Mumbai, Mumbai

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

ITA 7496/MUM/2025[2016-17]Status: DisposedITAT Mumbai09 Feb 2026AY 2016-17

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokarsa No. 157/Mum/2025 (Assessment Year: 2016-17)

For Appellant: Shri Ronak DoshiFor Respondent: Shri Ritesh Misra (CIT DR)

Section 143(3)Section 144Section 14ASection 234BSection 250Section 8D(2)(ii)

from the order of the Ld. Assistant Commissioner of Income Tax, Circle-21(3), Mumbai (for brevity the “Ld. AO”), order passed under section 143(3) of the Act, date of order 30.12.2018. 2 S.A. No.157/Mum/2025 The Sri Hari Trust 2. The assessee has taken the following grounds. GROUND

Nova Elevators Private Limited, Mumbai vs. ITO-13(1)(1), Mumbai

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

ITA 7248/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Feb 2026AY 2014-15

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokarnova Elevators Private Vs Ito -13(1)(1), Mumbai Limited Maharashtra-400020 402, Dimple Apts., 4E, Asha Nagar, Kandivali East, Mumbai-400101 Pan: Aadcn0305K Appellant Respondent Assessee By : Shri Sharad Patel, Ca Respondent By : Shri Leyaqat Ali Aafaqui, (Sr Ar) Date Of Hearing : 29/01/2026 Date Of Pronouncement : 09/02/2026 O R D E R Per: Anikesh Banerjee (Jm): The Instant Appeal Of The Assessee Filed Against The Order Of The Ld. Commissioner Of Income Tax (Appeal)-51, Mumbai [For Brevity ‘The Ld. Cit(A)], Order Passed Under Section 250 Of The Income Tax Act 1961 (For Brevity ‘The Act’) For Assessment Year 2014-15, Date Of Order 12.09.2025. The Impugned Order Emanated From The Order Of The Ld. Income-Tax Officer Ward-13(1)(1), Mumbai

For Appellant: Shri Sharad Patel, CAFor Respondent: Shri Leyaqat Ali Aafaqui, (SR AR)

Section 133(6)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 68

Income-tax Officer Ward-13(1)(1), Mumbai 2 Nova Elevators Pvt. Ltd. (for brevity the ‘Ld. AO’), order passed under section 143(3) r.w.s. 147 of the Act date of order 31.12.2018. 2. The assessee has taken the following grounds & additional grounds: “1. Misapplication of Section 68-Failure

Nobel Biocare India Private Limited, Mumbai vs. ACIT, 15(2)(1), Mumbai

ITA 6881/MUM/2025[2020-21]Status: DisposedITAT Mumbai09 Feb 2026AY 2020-21

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Ms. Hinal Shah &For Respondent: Mr. Leyaqat Ali Aafaqui, Sr. DR

return was selected for scrutiny and 115JB of the Act. The return was selected for scrutiny and assessment under section 143(3) of the Act was completed on assessment under section 143(3) of the Act was completed on assessment under section 143(3) of the Act was completed

Nobel Biocare India Private Limited, Mumbai vs. ACIT, Circle 15(2)(1), Mumbai

ITA 6880/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Feb 2026AY 2013-14

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Ms. Hinal Shah &For Respondent: Mr. Leyaqat Ali Aafaqui, Sr. DR

K M Textiles Export Private Limited, Mumbai vs. Income Tax Officer Ward 10(1)(1), Mumbai

In the result, appeal of the assessee is allowed and appeal filed by the Revenue is dismissed

ITA 6750/MUM/2025[2017-18]Status: DisposedITAT Mumbai09 Feb 2026AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 147Section 148Section 69C

National Faceless Appeal Centre, Delhi, for the assessment year 2017-18, arising out of reassessment framed under section 147 read with section 143(3) of the Income-tax Act, 1961. Since both the appeals emanate from the same impugned order and involve common facts and interlinked issues, they were heard

Income Tax Officer - 10(1)(1), Mumbai vs. K M Textiles Exports Pvt. Ltd., Mumbai

In the result, appeal of the assessee is allowed and appeal filed by the Revenue is dismissed

ITA 6614/MUM/2025[2017-18]Status: DisposedITAT Mumbai09 Feb 2026AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 147Section 148Section 69C

Income Tax Officer, Kalyan vs. Kala Eswaran Iyr, Dombivali

In the result, the appeal filed by the Revenue is dismissed

ITA 6237/MUM/2025[2020-2021]Status: DisposedITAT Mumbai09 Feb 2026AY 2020-2021

Bench: Shri Anikesh Banerjee & Shri Jagadish

Section 115BSection 132Section 143(3)Section 69A

Faceless Appeal Centre, Delhi, dated 17.06.2025 for the assessment year 2020- 21, arising from the order passed by Ld. Assessing Officer (AO) under Section 143(3) r.w.s 144B of Income Tax Act. 2. The only issue arising for our consideration is whether the Ld. CIT(A) was justified in deleting

Haresh Ravji Majethia, Mumbai vs. ACIT -29(1), Mumbai

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

ITA 5718/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Feb 2026AY 2014-15

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokarharesh Ravji Majethia Vs Acit-29(1) 1903 Tridev Chs, Bhakti Marg Room No.108, 1St Floor, C-10, Mulund West, Mumbai- Pratyakshakarbhawan, 400080 Bandrakurla Complex, Bandra East, Mumbai-400051 Pan:Aeqpm5542P Appellant Respondent Assessee By : Ms. Ritika Agarwal, Adv. (Virtually Appeared) Respondent By : Shri Ritesh Misra (Cit Dr) Date Of Hearing : 29/01/2026 Date Of Pronouncement : 09/02/2026 O R D E R Per: Anikesh Banerjee (Jm): The Instant Appeal Of The Assessee Filed Against The Order Of The Ld. Commissioner Of Income Tax Appeal Addl/Jcit-A To Vadodara [For Brevity ‘The Ld. Cit(A)], Order Passed Under Section 250 Of The Income Tax Act 1961 (For Brevity ‘The Act’) For Assessment Year 2014-15, Date Of Order 28.07.2025. The Impugned Order Emanated From The Order Of The Ld. Commissioner Of Income Tax 29(1)

For Appellant: Ms. Ritika Agarwal, Adv. (virtually appeared)For Respondent: Shri Ritesh Misra (CIT DR)

Section 127Section 143(3)Section 250Section 292BSection 68

order of the ld. Commissioner of Income Tax 29(1), 2 Haresh Ravj iMajethia Mumbai (for brevity the Ld. AO) order passed under section 143(3) of the Act date of order 26.12.2016. 2. The assessee has taken the following grounds: “1. BECAUSE, Id. CIT(A) erred

ACIT-4(1)(1), Mumbai vs. Bnp Paribas India Solutions Pvt Ltd, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 5688/MUM/2025[2017-18]Status: DisposedITAT Mumbai09 Feb 2026AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

For Appellant: Shri Niraj Sheth, AdvocateFor Respondent: Shri Vaibhav Jain, CIT DR

Section 143(3)

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

Balkrishna Peruvad Bhandari, Mumbai vs. Income Tax Officer, Ward 27(1)(1), Mumbai, Navi Mumbai

In the result, the appeal filed by the assessee is hereby allowed for statistical

ITA 5656/MUM/2025[2012-13]Status: DisposedITAT Mumbai09 Feb 2026AY 2012-13

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm Mr. Balkrishna Peruvad Bhandari, Income Tax Officer, 129, Creatie Industrial Premises, Ward 27(1)(1), 406, 4Th Floor, Tower No.6, Sundar Nagar Road No.2, Vs. Kalina, Santacruz (E), Vashi Railway Station Commercial Mumbai – 400 098 Complex, Vashi, Navi Mumbai - 400 703 Pan:Aaipb3921H (Appellant) : (Respondent)

For Respondent: Shri Leyaqat Ali Aafaqui, Sr. AR

Section 250Section 40Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI OM PRAKASH KANT, AM AND MS. KAVITHA RAJAGOPAL, JM

Blue Chip Financial Services Pvt Ltd, Mumbai vs. Income Tax Officer Ward 12(1)(3), Mumbai

In the result, appeal of the assessee is allowed

ITA 5616/MUM/2025[2012-13]Status: DisposedITAT Mumbai09 Feb 2026AY 2012-13

Bench: Shri Amit Shukla & Shri Girish Agrawalblue Chip Financial Services Vs Income Tax, Circle 12(1)(3) Private Limited Aayakar Bhavan, M.K. Road, 24, Dheeraj Heritage, 3Rd Floor, Churchgate Mumbai - 400020 S.V. Road, Santacruz West, Mumbai 400054 Pan: (Aaacb2087R) Appellant Respondent Present For: Appellant By : Shri Haridas Bhatt, Ca Respondent By : Shri Leyaqat Ali Aafaqui, Sr. Dr Date Of Hearing : 13.11.2025 Date Of Pronouncement : 09.02.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of National Faceless Appeal Centre (Nfac), Delhi Vide Din & Order No. Itba/Nfac/S/250/2025-26/1078465141(1) Dated 14.07.2025 Passed Against Assessment Order U/S. 143(3) R.W.S 147 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 30.12.2019 For Ay 2012-13. 2. Grounds Taken By The Assessee Are Reproduced As Under: “A) On The Facts & Circumstances Of The Case & In Law, The Cit(A) Erred In Confirming The Addition Made By The Ao Of The Alleged Unaccounted Money In The Form Of Accommodation Entry From Shell Company M/S Anubhav Commosale Pvt Ltd To The Extent Of Rs 20,00,055/- Treating It As Unexplained Income U/S 68 Of It Act.

For Appellant: Shri Haridas Bhatt, CAFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. DR

Section 131Section 133(6)Section 143(3)Section 148Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

Bharat Paper Mart, Mumbai vs. Assistatant Commissioner of Incme Tax Circle 17(1), Mumbai

In the result, ground no.1 raised by the assessee is allowed

ITA 5594/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Feb 2026AY 2013-14

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2013-14 Bharat Paper Mart Assistant Commissioner Of 219, Podar Chambers, S.A. Income Tax Circle-17(1), Mumbai Brelvi Road, Fort, Mumbai Vs. Maharashtra 400001 (Pan: Aajfb0186H) (Appellant) (Respondent) Present For: Assessee : Dr. K. Shivaram. Sr. Advocate Revenue : Shri Leyaqat Ali Aafaqui, Sr. Dr Date Of Hearing : 12.11.2025 Date Of Pronouncement : 09.02.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of National Faceless Appeal Centre (Nfac), Delhi, Vide Order No. Itba/Nfac/S/250/2025-26/1078818110(1), Dated 23.07.2025, Passed Against The Assessment Order By Assistant Commissioner Of Income Tax- 17(1)(2), Mumbai, U/S. 143(3) Of The Income-Tax Act (Hereinafter Referred To As The “Act”), Dated 04.03.2016 For Assessment Year 2013-14. 2 Bharat Paper Mart Ay 2013-14 2. Grounds Taken By Assessee Are Reproduced As Under: 1. The Learned National Faceless Appeal Centre (Nfac) Erred In Confirming Order Of Assessing Officer Disallowing Partner'S Remuneration Of Rs.31,30,490/- Paid To Working Partner Out Of Remuneration Of Rs.99,76,470/- Paid To Him Without Appreciating That Said Remuneration Was Paid In Accordance With The Provisions Of Section 40(B)(V) Of Income Tax Act 1961 & Hence The Disallowance Of Remuneration Of Rs. 31,30,490/- May Be Deleted. 2. The Learned Nfac Erred In Confirming Order Of Assessing Officer Taxing Commission Income Of Rs. 3,77,617/ On The Basis Of Form No. 26As Without Appreciating That Said Commission Income Was Not Taxable In A.Y. 2013-14 & Hence The Addition Of Rs. 3,77,617/- May Be Deleted. 3. The Appellant Craves Leave To Add, Amend, Alter Or Delete Any Of The Above Grounds Of Appeal.

For Appellant: Dr. K. Shivaram. Sr. AdvocateFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. DR

Section 143(3)Section 40

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

Kishore Anand Shetty, Goregaon East Mumbai vs. Circle 32(2), Mumbai

In the result, both the appeals of the assessee are allowed in terms indicated above

ITA 4975/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Feb 2026AY 2014-15

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 271(1)(c)Section 50CSection 54F

assessee against separate orders dated 24.07.2025 passed by the National Faceless Appeal Centre, Delhi, one arising out of the quantum assessment framed under section 143(3) of the Income-tax Act, 1961 for Assessment Year 2014-15 and the other arising out of the penalty proceedings initiated and levied under

Kishore Anand Shetty, Mumbai vs. Circle-32(2), Mumbai

ITA 4974/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Feb 2026AY 2014-15

Section 143(3)Section 271(1)(c)Section 50CSection 54F

Nakoda Developers, Mumbai vs. DCIT, Mumbai

ITA 4500/MUM/2025[2018-19]Status: DisposedITAT Mumbai09 Feb 2026AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

For Appellant: Shri Bhavesh Shah, ARFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. DR

Section 142A(6)Section 142A(7)Section 143(3)Section 56(2)(x)

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

DCIT-15(1)(1), Mumbai, Aayakar Bhavan Mumbai vs. Moksh Alloy Private Limited, Mumbai

In the result, the appeal of the Revenue is allowed for statistical purposes

ITA 4025/MUM/2024[2018]Status: DisposedITAT Mumbai09 Feb 2026

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopalassessment Year : 2018-19 Dcit-15(1)(1), Moksh Alloy Private Limited, Room No. 451, 1404, Tulip Regency Gardens, 4Th Floor, Vs. Sector 6, Aayakar Bhavan, Kharghar, Mumbai-400020. Navi Mumbai-410210. Pan : Aahcm4191J (Appellant) (Respondent) For Assessee : Ms. Krupa Gurav For Revenue : Shri Umashankar Prasad, Cit-Dr Date Of Hearing : 27-01-2026 Date Of Pronouncement : 09-02-2026 O R D E R Per Vikram Singh Yadav, A.M :

For Appellant: Ms. Krupa GuravFor Respondent: Shri Umashankar Prasad, CIT-DR

Section 143(3)Section 40Section 40A(3)Section 68Section 69C

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “D” BENCH : MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND MS. KAVITHA

Rajesh Sahu, Gurgaon vs. Assessing Officer, Nfau

In the result, appeal of the assessee is allowed

ITA 78/DEL/2026[2018-19]Status: DisposedITAT Delhi09 Feb 2026AY 2018-19

Bench: Shri Satbeer Singh Godaraassessment Year: 2018-19 Sh. Rajesh Sahu, Vs. Assessing Officer, H. No. 2A, Sahu Lane, New Delhi Phase-2, Ashok Vihar, Gurgaon Pan: Avaps9917M (Appellant) (Respondent) Assessee By None Department By Sh. Manoj Kumar, Sr. Dr

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(viii)Section 57

/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1082329643(1), dated 06.11.2025 involving proceedings under section 143(3) r.w.s. 263 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused. 2. It emerges ... under section 142(1) of the Act on 2 | P a g e 23.11.2020. The Ld. AO completed the assessment on 22.01.2021 under section 143(3) r.w. section 143(3A) and 143(3B) of the Act on income returned with the observation that on aforesaid two issues no addition

Ankit Agarwal, Noida vs. Income Tax Officer, Noida

Appeal is allowed

ITA 2/DEL/2026[2015-16]Status: DisposedITAT Delhi09 Feb 2026AY 2015-16

Bench: Shri Satbeer Singh Godara

Section 147Section 148Section 24

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER ITA No.2/Del/2026

Sanmati Packaging Private Limited, Delhi vs. Ward 22(3), Delhi

Appeal is partly allowed

ITA 188/DEL/2026[2017-18]Status: DisposedITAT Delhi09 Feb 2026AY 2017-18

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18 Sanmati Packaging Pvt. Ltd., Vs. Ito, 178, Ground Floor, Ward-22(3), Dayanand Vihar, Delhi New Delhi Pan: Aaqcs6374L (Appellant) (Respondent) Assessee By Sh. Ankush Jain, Ca Department By Sh. Manoj Kumar, Sr. Dr

Section 115BSection 143(3)Section 68

/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2024-25/1064557694(1), dated 01.05.2024 involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused. 2. The assessee/appellant, admittedly