2024 (3) TMI 545

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.... Revenue : Shri Shridhar Dora, Sr.DR ORDER PER BENCH : These assessee's seven appeals for assessment years 2009-2010 to 2015-2016, arise against the National Faceless Appeal Centre [in short "NFAC"] Delhi's as many orders as its Dins and Orders Nos.ITBA/NFAC/S/250/2021- 22/103440136(1); 103440161(1); 103440199(1); 103440215(1); 1042060010(1); 103440238(1) and 103440277(1); all dated 27.07.2021,....

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....atiji [1987] 167 ITR 471 (SC) that all such technical aspects must make way for the cause of substantial justice. 3. Next comes the assessee's identical sole substantive grievance challenging the learned lower authorities action taking recourse to sec. 154 rectification thereby treating it as an "assessee-in-default" u/sec. 201 r.w.s. 201(1A) of the Act for the purpose of recovering the correspon....

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....er took-up yet another sec. 154 rectification in the impugned second round dated 29.11.2019 that the assessee's foregoing payments duly attracted TDS deduction u/sec. 194I of the Act whose non-compliance would liable it to be treated as the assessee-in-default. We are of the view in this clinching factual backdrop that such a course of rectification of the issue involving detailed enquiries would ....