2026 (6) TMI 853

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....llant : Shri Piyush Kaushik, Advocate For the Respondent : Ms. Monika Singh, CIT DR ORDER PER SANJAY AWASTHI, ACCOUNTANT MEMBER: 1. These are a batch of two appeals pertaining to the same assessee and for the sake of convenience these two appeals are being disposed of through a single order. ITA No.8020/Del/2025 (AY 2016-17) arises from order dated 06.11.2025, passed u/s. 250 of the....

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....ior to the issue of notice u/s. 148 of the Act and the Ld. AO has not obliged him with a copy of the same. It is also seen that the assessee has reported his request for reasons for reopening even before the Ld. CIT(A) but the same have not been provided at either of the two stages. Needless to say, the Ld. CIT(A) has upheld the Ld. AO's order and dismissed the appeal of the assessee. 2.1 Aggri....

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.... Ld. AO was repeatedly asked to provide the reasons for reopening (page 9 of the PB, regarding submission dated 26.03.2022 for AY 2016-17) and submission dated 11.08.2021 for AY 2017-18 through which the reasons for reopening have been asked to be shared with the assessee. The Ld. AR pointed out that even before the Ld. CIT(A) this issue was raised but was unfortunately summarily dismissed. The Ld....

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.... our notice here through this case law was that the notices should have been issued on 31.03.2021 and should have gone out of the control of the Ld. AO within 31.03.2021 itself. It was argued that merely signing of notice is not issuance of the same but issue of the notice would be considered when the same would go out of the control of the Assessing Officer. It was the submission that on two coun....