2025 (9) TMI 1660

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....aj Kumar Jain, Sr. DR ORDER PER SATBEER SINGH GODARA, JM This assessee's appeal for assessment year 2011-12, arises against the Commissioner of Income Tax (Appeals)-3 [in short, the "CIT(A)"], Noida's order dated 20.06.2024 passed in case no. CIT(Appeal) Kanpur-4/10583/2018-19 involving proceedings under section 147 r.w.s. 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'th....

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....assessee's above failure in 5th para at page 27, and, therefore, we ought to uphold the same in very terms. 5. We have given our thoughtful consideration to the foregoing rival pleadings and find no reason to express our agreement with the impugned reopening, inter alia, in light of the clinching facts emanating from the case file that the assessee-company had filed its original return on 25th ....