2025 (4) TMI 158

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..... entre, Delhi (hereinafter referred to as the "Ld. CIT(A)"] dated 13.05.2023 for the AY 2012-13. 02. The issue raised in ground no. 1 is a legal issue and is against the order of ld. CIT (A) upholding the assessment order passed u/s 147/143 of the Act pursuant to the proceeding u/s 148 of the Act, which were invalid and void ab initio. 03. The facts in brief are that the assessee filed the return .....

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..... 00/- on account of professional income received by the assessee which was not disclosed in the return of income, ii) Rs. 47,775/- u/s 40(A)(3) of the Act and iii) Rs. 6,24,180/- u/s 40(a)(ia) of the Act. 04. The assessee challenged the order before the ld. CIT (A) on legal issue as well as on merit, however, the appeal of the assessee was dismissed by the ld. CIT (A). 05. After hearing the rival .....

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..... d, the ld. PCIT stated 'fit case, approved' and no satisfaction was recorded by the ld. PCIT before granting the approval. The case of the assessee is squarely covered by the decision of Hon'ble Delhi High Courtin case of Capital Broadways Pvt. Ltd. Vs. ITO in WP(C) 4303/ 2017 dated 03.10.2024, wherein the Hon'ble court has decided the similar issue by holding that mere mechanical manner o .....

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