2024 (10) TMI 1668

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....l Mukherjee, JCIT. ORDER PER RAJESH 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 iss....

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.... 4. After hearing the rival contentions and perusing 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 p....