2025 (7) TMI 898

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....hattacharjee, Adv., Mr. Ankan Das, Adv. and Ms. Shradhya Ghosh, Adv. For the Respondent : Mr. Sanjay Dixit, Adv. and Mr. Rajeev Kumar Agarwal, Adv. ORDER THE COURT: We have heard the learned Advocates for the parties. There is a delay of 45 days in filing the appeal. As the explanation offered for not preferring the appeal within the period of limitation is acceptable, the delay in filing the ....

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....lkata Bench, was never raised by the appellant assessee before the Learned CIT (A) in their Grounds of Appeal nor during the Appellate Proceedings while filing additional grounds/evidences under prescribed Rules? II. Whether the Learned Income Tax Appellate Tribunal has committed substantial error in law in not appreciating the facts and circumstances of the case in correct perspective with reg....

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....d the case was re-opened after obtaining the due approval of competent authority as was required under section 151 of the Income Tax Act, 1961? We have elaborately heard the learned Advocates appearing for the parties and perused the orders passed by the First Appellate Authority as well as the impugned order passed by the learned Tribunal. The issue which falls for consideration is whether the ....