2024 (4) TMI 648

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....dmahshali, Accountant Member For the Assessee : Mr Sourabh Kulkarni ['Ld. AR'] For the Revenue : Mr Keyur Patel ['Ld. DR'] ORDER PER G. D. PADMAHSHALI, AM; The Revenue is in appeal against the order dt. 27/09/2023 of Commissioner of Appeals-13, Pune [in short 'CIT(A)] passed u/s 250 r.w.s. 254 of the Income-tax Act, 1961 [in short 'the Act'] in Appeal No PN/CIT(A)-13/ACIT, Company C....

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.... of Ld. CIT(A) for de-nova adjudication. In remand proceedings, the Ld. CIT(A)-13, Pune following his own adjudication/decision in AY 2014-15 in assessee's case, allowed the appeal by impugned order dt. 27/09/2023, against which both the rival parties are before us in similar way as they were before. 3. Without touching threefold issues brought to our notice by the rival parties i.e. (i) jurisd....

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....ibunal should be based on the location of the Assessing Officer. The Hon'ble Supreme court's decision in 'PCIT Vs ABC Papers Ltd.' (supra), has put the issue of jurisdiction of appellate forum to rest by holding that, the 'situs of the assessing officer' is the only key factor for determining the jurisdiction of appellate forum irrespective of any administrative order passed u/s 127 of the Act in ....