2026 (1) TMI 744

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....PER YOGESH KUMAR, U.S. JM: The present appeal is filed by the assessee against the order of the ld. Commissioner of Income Tax(Appeals)/National Faceless Appeal Centre, New Delhi (in short 'Ld. CIT(A)') dated 05.09.2024 for the Assessment Year 2011-12. 2. The assessee has raised following grounds of appeal:- "1. That in view of the facts and circumstances of the case, the Ld. CIT(A)....

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....r notice u/s 142(1) of The Income Tax Act,1961 has been issued after the assessee filed and verified the return of income on 19/11/2028 in response to notice us 148, which is bad in law so the assessment order passed u/s 147/143(3) and 147/144 of The Income Tax Act, 1961 is void ab-initio. 4. That on the facts and circumstances of the case and in law the Ld CIT(A) has erred by not conside....

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....tice u/s 148 dated 30.10.2018. The assessment order came to be passed u/s 143(3)/147 of the Act on 12.12.2018 by making an addition of Rs. 50,50,000/- u/s 69 of the Act on account of unexplained investment. 4. Aggrieved with the assessment order dated 12.12.2018, Assessee preferred appeal before the Ld. CIT(A). The ld. CIT(A) vide order dated 05.09.2024, dismissed the appeal of the assessee. As....

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....re, sought for dismissal of the Appeal. 7. We have heard both the parties and perused the material available on record. As could be seen from the assessment order, the A.O. has not considered the revised return dated 30/10/2018 filed by the Assessee on the ground that 'e-verification of the said return is still pending'. The Ld. Assessee's Representative produced the copy of the revised ret....