2025 (8) TMI 33

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....1-12, arises against the CIT(A)/NFAC, Delhi's DIN & order No. ITBA/NFAC/S/250/2024-25/1070503578(1) dated 20.11.2024, in proceedings u/s 147 r.w.s. 144 of the Income Tax Act, 1961 (in short "the Act"). 2. Heard both the parties at length. Case file perused. 3. It emerges at the outset that there arises the first and foremost issue of validity of impugned reopening itself as the learned Asses....