2025 (5) TMI 1426

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....e Petitioner Through: Mr. V. K. Sabharwal, Mr. R. B. Gupta and Mr. Rajiv Kumar, Advocates. For the Respondent Through: Mr. Punit Rai and Mr. Yojit Pareek, Advocates. VIBHU BAKHRU, J. (ORAL) 1. The petitioner has filed the present petition impugning a notice dated 07.10.2024 [impugned notice] issued under Section 154 of the Income Tax Act, 1961 [the Act] as well as the order [impugned orde....

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....oner any opportunity of being heard. The petitioner challenged the said decision by filing an appeal before the Commissioner of Income Tax (Appeals) [CIT(A)] on 17.08.2021. 4. The CIT(A), by an appellate order dated 30.07.2024, allowed the appeal and set aside the rectification order dated 05.07.2021 on the ground that the said order was passed without issuance of any notice to the petitioner. ....

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....pportunity of being heard, and therefore, the grounds on which the earlier decision had been set aside, stood addressed. 7. However, we find that there is another ground of challenge, which merits consideration. It is the petitioner's case that, while its appeal before the CIT(A) was pending, it had also filed a rectification application dated 19.11.2022 before the CPC against the intimation en....