2023 (8) TMI 443

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....r.DR ORDER PER ANNAPURNA GUPTA, ACCOUNTANT MEMBER Present two appeals have been filed by the Revenue against orders passed by the ld. Commissioner of Income Tax (Appeals)-12, Ahmedabad [hereinafter referred to as "Ld.CIT(A)"] of even dated 24.3.2022 passed under section 250(6) of the Income Tax Act, 1961 [hereinafter referred to as "the Act" for short]for the Asst. Year 2012- 13 and 2013-14 vid....

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....e, which is subjudice before Hon'ble Apex Court. ii) It is, therefore, prayed that the order the AO may be restored to the above of the case and in law, the Ld.CIT(A) has erred in assessing Officer under Sec. 271.(l)(c) of the Act of grounds taken by the assessee, without appreciating and by simply observing that the Hon'ble ITAT has and also without appreciating that the decision of the technic....

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....ntum of appeals of the assessee in IT(SS)A.No.265 & 266/Ahd/2019 for the above two assessment years and deleted both quantum additions vide common order dated 22.11.2021. A copy of the order of the Tribunal is placed on record. 4. In the penalty proceedings before the first appellate authority, the assessee brought to the notice the factum of Tribunal's order being passed in quantum appeals of th....