2025 (1) TMI 97

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....021-22, arises against the Commissioner of Income Tax (Appeals) [in short "CIT(A)"], Delhi's DIN and order no. ITBA/APL/M/250/2024- 25/1066193370(1), dated 28.06.2024 involving proceedings under section 271DA of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'). 2. Heard both the parties at length. Case file perused. 3. Coming to the assessee's first and foremost legal ground that ....