Sahyadri Erectors Private ... vs National E-Assessment Centre, Delhi, ... on 12 March, 2026
8. We have carefully considered the contentions of the assessee,
perused the records and have also gone through the relevant provisions
of the Act. We have also perused the citations relied upon qua facts on
record. It appears that the ld.CIT(A) has brushed aside the grounds of
appeal in this regard without analysing it from the facts on record. No
factual report in this regard appears to have been called from the AO.
Further, there is no discussion as to why the cases laws relied upon were
not applicable to the facts of the case. The relevant provisions have not
be examined to find out their applicability to the facts of the case.
Relevant extracts of the order in the case of Trendsutra Client
Services Pvt. Ltd vs Assistant Commissioner of Income Tax in
WP 1083 of 2021 on 14 September, 2021 reproduced as below for
the sake of brevity: