9911796707
TMI Blog2025 (4) TMI 1361X X X X Extracts X X X X X X X X Extracts X X X X ..... s assessee's appeal for assessment year 2020-21, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the "CIT(A)/NFAC"], Delhi's DIN and order no. ITBA/NFAC/S/250/2023-24/1059720469(1), dated 15.01.2024, involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'). 2. Case called twice. None appears at ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tement that the said cash represented liquor sale receipts of the shop located at Premnagar, Dehradun, which was run by Smt. Sarita, who happened to the member of assessee AOP M/s. Maya & Co. The Principal Director of Income Tax (PDIT) thereafter issued his warrant on 06.04.2019 requisitioning the said cash, which in turn, led to section 69 r.w.s. 115BBE addition made in the assessee's hands. The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t. 7. We are of the considered view that the Revenue's arguments carry no merit once it is a case of a "requisition" and the learned Assessing Authority has framed its assessment under the regular provisions i.e. under section 143(3) of the Act than either taking recourse of section 148/147, as the case may be. We thus see no reason to sustain the impugned assessment framed on 31st March, 2022, w ..... X X X X Extracts X X X X X X X X Extracts X X X X
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