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2020 (4) TMI 233

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....ER 1. This appeal, under section 260A of the Income Tax Act, 1961, has been taken out in respect of a judgment and order of the learned Income Tax Appellate Tribunal, Delhi Bench (S.M.C.), New Delhi, dated 3rd October, 2019. The appellant has essentially tried to make out a case on two questions of law, which, according to the learned advocate appearing for the appellant, are substantial question....

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....pellant raised a ground that the address on which the notices were sent by the Ld. AO being "Manoj Kumar Sharma, Nai Abadi, Dadri, G.B. Nagar" was not the correct address as there could be more than one Manoj or Manoj Kumar or Manoj Kumar Sharma in Dadri and the post office might have ended up serving the notices of the Ld. AO to any one of those persons named Manoj. It was contended by the appell....

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.....T. Act, 1961 be not imposed on the appellant. A copy of the said notice has been placed on the record of this office under self authentication by the appellant. It is seen that the said notice vide F. No. ITO/W2( 2)/Noida/271(1) (c)/201718 dated 04.05.2017 file F. No./PAN/229/148 was issued on the same address on which the Ld. AO has issued earlier notices, i.e., Manoj Kumar Sharma, Nai Abadi, Da....

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....ew of the admission of the appellant the claim of the appellant that it did not receive the notices issued by the Ld. AO because of the address on which the said notices were sent by the Ld. AO was either incomplete or incorrect is not tenable." 4. So far as the second question is concerned, the answer to the same is at paragraph 8 of the said order of the Commissioner of Income Tax (Appeals)I da....