2024 (10) TMI 1668

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.... KUMAR, AM: This is the appeal preferred by the revenue against the order of the Ld. Commissioner of Income Tax (Appeals)-NFAC, Delhi (hereinafter referred to as the "Ld. CIT(A)"] dated 02.04.2024 for the AY 2012-13. 2. At the outset, the Ld. Counsel for the assessee submitted that this is the revenue appeal but the revenue has not taken any legal issue challenging the appellate order of Ld. CI....

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....using the material on record, we find that the Ld. CIT(A) has allowed the appeal on legal issue of reopening of assessment by recording a finding that the issue has already been examined in the original assessment proceedings which culminated in passing the order u/s 143(3) of the Act dated 31.03.2014. Therefore the issue raised in the reassessment proceedings u/s 147 of the Act is on the basis of....