2025 (6) TMI 476

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....DR ORDER PER ANUBHAV SHARMA, JM: This appeal is preferred by the assessee against the order dated 05.07.2023 of the Commissioner of Income-tax (Appeals)-3, Gurgaon (hereinafter referred to as the Ld. First Appellate Authority or 'the Ld. FAA', for short) in Appeal No.10479/2019- 20 arising out of the appeal before it against the order dated 28.12.2019 passed u/s 143(3) r.w.s. 153B(1)(b) o....

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.... Karnal, seeking approval in respect of Skylark Foods Pvt. Ltd. was received by the approving authority, i.e., JCIT, Chandigarh, on 24.12.2019 and the approval was granted on the same date. The ld. Counsel for the assessee has relied the order of the coordinate Bench in ITA No.2545/Del/2023, M/s Skylark Hatcheries Pvt. Ltd. vs. DCIT, order dated 27.02.2025, to contend that the coordinate Bench has....

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....andigarh. Then, we find that on 25/26.12.2019, by way of letters No. JCIT/RC/Chd/CC-KNL/OSD/184/2019-20/187/529 to 534; and JCIT/RC/Chd/CCKNL/ OSD/190/2019-20/187/649; approval was granted. Although, the approval letters are separately issued for each assessment year. However, on going through the approval, we find that the approval letter does not bear any reference to what all material were cons....

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.... vs. Shiv Kumar Nayyar, 2024 (6) TMI 29, we are inclined to allow the additional ground. 7. Consequently, the appeal is allowed and the impugned assessment is quashed. Order pronounced in the open court on 09.05.2025. ============= Document 1 Office of the Joint Commissioner of Income Tax, Central Range, कार्यालय संयुक....