2025 (6) TMI 1382

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....t : Sh. Rajesh Kumar Dhanesta, Sr. DR And Ms. Neha Chaudhary, CIT(DR) ORDER PER SATBEER SINGH GODARA, JM This assessee's appeal for assessment year 2015-16, 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/250/2023-24/1056264034(1), dated 19.09.2023 involving proceedings under section 1....

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....as been wrongly made in its hands. The Revenue is equally fair in not disputing the clinching fact that there is no discussion in the assessment order to this effect nor the assessee's plea has been rejected in specific terms in the lower appellate discussion. 5. Be that as it may, we are of the considered view that once the assessee has raised the instant legal argument, it is deemed appropriate....