2025 (2) TMI 1694

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....tment : Dr. Arun Kumar Yadav, CIT(DR) ORDER PER SATBEER SINGH GODARA, JUDICIAL MEMBER: This assessee's appeal for assessment years 2018-19 arises against the Pr. Commissioner of Income Tax-1(in short, the "PCIT), Agra's order no. F.No. PCIT-1/Agra/Sec.263/PUACPL/2022-23 dated 21.03.2023, involving proceedings under section 263 of the Income-tax Act, 1961 (hereinafter referred to as 'the A....

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....i Agro Cold Care vs. ITO dated 24.08.2021 (headed by one of us i.e. Judicial Member), that the issue already stands settled in the department's favour. 4. We have given our thoughtful consideration to the issue. We are of the considered view that given the fact that the assessee in fact duly carries out his business of cold storage, merely because it had given on rent the corresponding cold sto....