2025 (4) TMI 1953

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....pondent : Shri Shailender Srivastava, Sr. DR ORDER PER BRAJESH KUMAR SINGH, AM, This appeal filed by the assessee is directed against the order dated 26.12.2024 of National Faceless Appeal Centre, Delhi, relating to Assessment Year 2012-13 arising out of order u/s 271(1)(c) of the Income Tax Act, 1961 (hereinafter referred to 'the Act') dated 16.03.2024. 2. At the outset in this case, ....

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....inding of the Tribunal is reproduced hereunder:- "3. We come to the first and foremost legal issue of the validity of the impugned reopening itself. A perusal of the case file at page 56 indicates that the learned Assessing Officer's reopening reasons had nowhere even indicated that the assessee didn't disclose all the relevant particulars, 'fully' and 'truly' in the first round of assess....