2026 (3) TMI 379

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.... PER YOGESH KUMAR, U.S. JM: The present appeal is filed by the Assessee against the order of Ld. Commissioner of Income Tax (Appeals), ADDL/JCIT(A), Thane, ('Ld. CIT(A)' for short), dated 20/01/2025 for the Assessment Year 2021-22. 2. Brief facts of the case as mentioned in the order of the Ld. CIT(A) are as under:- "The Assessee filed its return of income on 28/02/2022 declaring....

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....d the Appeal filed by the Assessee on 20/01/2025. As against the order of the Ld. CIT(A) dated 20/01/2025, Assessee preferred the captioned appeal. 4. The Ld. Counsel for the Assessee vehemently submitted that the CPC has no jurisdiction to issue suo-moto order of rectification without issuing prior show cause notice specified under Section 154(3) of the Act, therefore, submitted that the order....

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....s per previous order(s)', a sum of Rs. 64,21,690/-has been mentioned, whereas, as per the intimation u/s 143(1) of the Act dated 30/09/2022 (which is rectified vide order u/s 154 dated 01/11/2022), the amount of refund issued to Assessee was mentioned as Rs. 58,74,830/-. On going through the record, it is found that there is one more order passed u/s 154 of the Act dated 01/11/2022 has been issued....