2023 (11) TMI 393

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....Adv. For the Revenue : Shri Ramnath P. Murkunde ORDER PER SATBEER SINGH GODARA, J.M. : This assessee's appeal for assessment year 2005- 2006, arises against the National Faceless Appeal Centre [in short "NFAC"] Delhi's Din and Order No. ITBA/NFAC/S/ 250/2023-24/1054836440(1), dated 03.08.2023, involving proceedings u/s. 271(1)(c) of the Income Tax Act, 1961 (in short "the Act"). Hea....

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....ery much akin to an assessment giving rise to recovery of tax demands and therefore, the assessee's legal representatives are liable for the corresponding default u/sec.271(1)(c) in light of sec. 159(1) to (6) of the Act. 4. We find that the instant issue is no more res integra in light of [2019] 417 ITR 45 (Madras) CIT vs. Gowri decided against the department, as upheld in SLP (Civil) No.26378....