2026 (3) TMI 1726

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.... Addl. CIT, Sr. DR ORDER Per Rajesh Kumar, AM The present appeal filed by the revenue arises from order dated 12.04.2025 passed u/s 250 of the Income Tax Act, 1961 (hereafter "the Act") by the Ld. Commissioner of Income Tax (Appeals)-Kolkata 27 [hereafter "the Ld. CIT(A)]. 2. The issue raised in Ground No. 1 is against the order of Ld. CIT(A) annulling the assessment framed u/s 147/143....

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..../s 148A(b) of the Act was issued and after following the procedure laid down under the Act order u/s 148A(d) of the Act was passed on 27.03.2023. Finally, notice was issued u/s 148 of the Act was issued on 30.03.2023. Thereafter, statutory notices along with questionnaire were issued and served upon the assessee. The assessee also filed full details in compliance. Finally, assessment was framed u/....

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.... 151 taxman.com 489 (SC), in the case of Shyam Sunder Khandelwal Vs. ACIT reported in [2024] 161 taxmann.com 255 (Rajasthan) and Sejal Jewellary Vs. UOI [2025] 171 taxman.com 846 (Bombay HC). 5. After hearing the rival contention and perusing the material available on record, we find that incriminating material on the basis of which proceeding u/s 147/148 of the Act were initiated apparently on....