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2023 (1) TMI 1504

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....ilak Mitra, Adv. ...for appellant. Mr. Avratosh Mazumder, Sr. Adv. Mr. Avra Mazumder, Adv. ..for respondent The Court : - We have heard Mr. Tilak Mitra, learned standing counsel for the appellant and Mr. Avratosh Mazumder, learned Senior Advocate for the respondent assessee. There is a delay of 244 days in filing the appeal. We have perused the affidavit filed in support of the petitioner....

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....der to admit new additional grounds which is in violation of Rule 46A of the I.T. Rule 1962 ? ii) Whether on the facts and circumstances of the instant case and in law the Learned Income Tax Appellate Tribunal has erred in holding that the notice under section 143(2) of the Act issued by the Assessing Officer as non-est, while the issuing assessing officer, had jurisdiction over the asses....