2025 (12) TMI 1342

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....u Bhasin, Adv For the Revenue : Sh. Rajesh Kumar, CIT DR ORDER PER YOGESH KUMAR, U.S. JM: The captioned appeals are filed by the Revenue against the orders of Ld. Commissioner of Income Tax (Appeals)-25 ('Ld. CIT(A)' for short), New Delhi dated 28/02/2025 for the Assessment Year 2011-12 & 2012- 13 respectively. 2. The Ld. Counsel for the Assessee submitted that the A.O. made protect....

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....ra) and by the Tribunal in the case of M/s Transline Technologies Ltd. (supra), squarely applicable, thus sought for dismissal of the Appeals of the Revenue. 3. Per contra, the Ld. Departmental Representative relying on the assessment orders, sought for allowing the Appeals. 4. We have heard both the parties and perused the material available on record. The Co-ordinate Bench of the Tribunal ....

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....ds, date of becomes date of search in the case of nonsearched person the assessee in the present case]. In the instant case of the assessee (non-searched person), as the satisfaction i.e. 17/02/20222. In light of the decision of the Hon'ble Supreme Court and Delhi High Court [supra], the impugned A.Y 2011-12 and AY 2012-13 would, therefore, fall beyond the period of six/ten a....