2025 (5) TMI 1786

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....ODARA, JM This assessee's appeal for assessment year 2012-13, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the "CIT(A)/NFAC"], Delhi's DIN and order no. ITBA/NFAC/S/250/2023-24/1057415445(1), dated 26.10.2023, involving proceedings under sections 143(3) r.w.s. 147 of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'). 2. Case....

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....nated in reassessment in question, dated 23.10.2018 adding the foregoing sums which stand upheld in the lower appellate proceedings as well. It is clear in this factual background that the learned Assessing Officer had initiated the impugned reopening beyond a period of four years from the end of the relevant assessment year and therefore hit by section 147 1st proviso. The Revenue seeks to buttre....