2025 (6) TMI 782

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.... For The Assessee : Shri Deepak Ostwal, CA & Shri Vishal Agarwal, Adv. For The Department : Shri Om Prakash, Sr. DR ORDER PER YOGESH KUMAR U.S., JM The above appeals are filed by the Assessee challenging the order of the Ld. CIT(Appeals) dated 16/03/2012 on the quantum and order dated 26/12/2018 on the penalty issued u/s 271(1)(c) of the Income Tax Act, 1961 ('Act' for short). The Asse....

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....itted that the notice u/s 143(3) of the Act has been duly issued on the Assessee and Assessee has participated in the assessment proceedings, therefore, relying on the orders of the lower authorities sought for dismissal of the appeal. 4. We have heard the parties and perused the material on record. It is the specific contention of the Ld. AR that no notice u/s 143(2) of the Act has been issued....

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....ued to the Assessee for the year under consideration and without issuing the notice u/s 143(2) of the Act, the impugned assessment order has been framed by the Assessing Officer. Thus, the assessment order is liable to be set aside. Accordingly, we allow additional grounds of appeal of the Assessee and quash the assessment order dated 23/12/2019 passed u/s 147/143(3) of the Act. As we have allowed....