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2025 (5) TMI 1480

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....an Kumar Nath, Adv. For The Department : Sh. A.S. Rana, Sr. DR ORDER PER SATBEER SINGH GODARA, JM These assessee's twin appeals for assessment year 2020-21 and 2021-22, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the "CIT(A)/NFAC"], Delhi's orders, both dated 21.08.2024, having DIN and orders no. ITBA/NFAC/S/250/2024-25/1067796533(....

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....1 exemption disallowance. The Revenue's case, more particularly, is that the assessee is barred by the principle of stricter interpretation from claiming section 11 exemption relief herein once it has failed to ensure compliance of filing of tax audit report in Form 10B within the prescribed due date of filing of return under section 139(1) of the Act. Its case in other words is that the above com....