2022 (12) TMI 1604

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....charyya For the Appellant : Mr. Soumen Bhattacharjee, Adv. For the Respondent : Mr. S.M. Surana, Adv. ORDER GA/1/2022 1. The Court :- Heard learned Counsel for the respective parties. 2. There is a delay of 903 days in filing the appeal. 3. Though we are not fully satisfied with the reasons assigned in the affidavit filed in support of the petition for condonation of delay, ye....

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....in upholding the order of the Learned Commissioner of Income Tax (Appeal), quashing the order of the Assessing Officer under section 147/144 of the Income Tax Act, 1961 for non-issuance of notice under section 143(2) of the Act, without appreciating the facts that assessee did not comply with the notice under section 148 of the Income Tax Act, 1961 and as such notice under section 143(2) of the In....