2025 (6) TMI 2089

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....ue : Shri Arun Kanti Datta, CIT, D/R ORDER PER NARENDRA KUMAR BILLAIYA, AM: This appeal by the assessee is preferred against the order of ld. Pr. CIT, Mumbai - 5 [hereinafter "the ld. Pr. CIT"] dated pertaining to AY 2018-19. 2. The sum and substance of the grievance of the assessee is that the ld. Pr. CIT erred in assuming jurisdiction u/s 263 of the Act further erred in holding ....

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....ness related. The ld. Pr. CIT further supported his belief by the explanatory notice to the Finance Bill, 2014 (CBDT Circular No. 1/2015 dated 21/01/2015). 6. We have given a thoughtful consideration to the order of the ld. Pr. CIT. We are of the considered view that the issue raised by the ld. Pr. CIT is a highly debatable issue as the Co-ordinate Benches of the Tribunal have taken a consisten....

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....022. 8. In the result, appeal of the assessee is allowed. Order pronounced in the Court on 20th June, 2025 at Mumbai. ============= Document 1 GOVERNMENT OF INDIA MINISTRY OF FINANCE INCOME TAX DEPARTMENT OFFICE OF THE PRINCIPAL COMMISSIONER OF INCOME TAX PCIT, Mumbai-5 To. RPG LIFE SCIENCES LIMITED RPG HOUSE, 4TH FLOOR DR ANNIE BESANT ROAD , Worli Colony S.O Mumbai MUMBAI 400030 , M....

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.... attendance is not required. You also have the option to file your submission from the e filing portal using the link: incometaxindiaefiling.gov.in MENT In this case, opportunity of being heard was given to the assessee regarding the revision petition u/s 263 of the Income Tax=Act. 1961 vide notice dated 06.03.2025 fixing the haring on 12.03.2025. In response, the assessee has file submissio....