2025 (5) TMI 207

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.... Advocate. For the Revenue : Sh. Sahi l Kumar Bansal, Sr. DR ORDER PER YOGESH KUMAR, U.S. JM: This appeal is filed by the Assessee against the order of the Commissioner of Income Tax (Appeals)-3, Noida ('Ld. CIT(A)' for short) dated 26/02/2024 for the Assessment Year 2016-17. 2. Brief facts of the case are that, the Assessee filed return of income declaring total income at Rs. 3,36,....

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....as raised several grounds challenging the validity of assumption of jurisdiction u/s 147 of the Act, in correct recording of reasons together with merits and also argued vehemently on the recording of incorrect reasons, we deem it fit to first address the assumption of jurisdiction u/s 147 of the Act. 4. We have heard the rival submissions and perused the material available on record. In the pr....

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.....com 390 (MP HC). 5. The Special Leave Petition (SLP) filed by the revenue against the order of Hon'ble High Court of Madhya Prdadesh in the case of S. Goyenka Lime and Chemicals Ltd (supra) has been dismissed by the Hon'ble Supreme Court reported in 64 taxmann.com 313. Further, we find that the Hon'ble Jurisdictional High court in the case of PCIT Vs. NC Cables Ltd reported in 391 ITR ....

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.... which can be reflected in the briefest possible manner. In the present case, the exercise appears to have been ritualistic and formal rather than meaningful, which is the rationale for the safeguard of an approval by a higher ranking officer. For these reasons, the Court is satisfied that the findings by the ITAT cannot be disturbed. 12. The substantial questions of law framed are answer....