2025 (9) TMI 696

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.... the assessee is directed against the order of Commissioner of Income Tax (Appeals)/Additional/Joint Commissioner of Income Tax-(Appeals)-2, Mumbai (hereinafter referred to as 'the CIT(A)') dated 20.02.2024, for assessment year 2008-09 2. This appeal is time barred by 6 days. The assessee has filed an application for condonation of delay. The reason for delay in filing of appeal appears....

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....portunity of being heard to the assessee." 4. The assessee in appeal had assailed validity of notice issued u/s. 148 of the Act as well as reopening of assessment. Since objections of the assessee against reopening were not decided by the AO vide separate order, the Tribunal restored appeal back to the AO with a direction to first decide objections of the assessee against reopening of assessmen....

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....cuments on record, I find that in compliance of directions of the Tribunal dated 08.01.2019 the AO had decided objections of the assessee against reopening of assessment vide separate order. Thus, the condition set out by the Hon'ble Apex Court in the case of GKN Drive Shafts India Ltd. vs. ITO 259 ITR 19 appears to have been complied with. The grievance of the assessee raised before the Tribunal ....