2024 (5) TMI 1017

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.... For the Revenue : Shri Shakeer Ahamed, DR ORDER PER MADHUSUDAN SAWDIA, A.M: The captioned appeal has been filed at the instance of Jai Balajee Security Services Pvt. Ltd., ('the assessee'), against the order dated 24/11/2022, passed by the learned Commissioner of Income Tax (Appeals)-National Faceless Appeal Centre (NFAC), Delhi ("Ld. CIT(A)"), relating to the assessment year (AY) 2020-2....

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....o have appreciated that CPC-Bangalore/Assessing Officer could not have made a prima facie adjustment since the expression prima facie adjustment limits the jurisdiction of the Assessing Officer to issues wherein two views are not possible and thus the Ld. CIT(Appeals) erred in upholding the order passed by the Assessing Officer. 4. For these and other grounds that may be urged at the time....

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....otal income of the assessee at Rs. 7,08,58,140/-. 4. Aggrieved, assessee preferred appeal before the Ld.CIT(A). Ld.CIT(A), considering the facts of the case, sustained the addition made by CPC and dismissed the appeal of the assessee. 5. Feeling aggrieved with the order of the Ld. CIT(A), the assessee is now in appeal before the Tribunal, raising as many as four grounds. 6. At the time of....

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....aised by the assessee regarding the rectification order passed by the CPC u/s 154 of the Act, which is bad in law, since rectification order itself lacks jurisdiction being passed without issuance of original intimation u/s. 143(1) of the Act. 8.1. In these circumstances, in the interest of justice, we are of the view that a fresh opportunity should be given to the assessee and, accordingly, we....