2026 (4) TMI 1912

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....IVASTAVA, SR. DR ORDER PER M. BALAGANESH, AM : 1. By virtue of this Miscellaneous Application, the assessee is seeking recall of the order passed by this Tribunal in ITA No. 129/Agr/2023 dated 24.06.2025. 2. At the outset, we find that the registry had notified to the assessee that there is a delay in filing of this miscellaneous application by 48 days. But on perusal of the records, w....

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....il and no decision was given by the Tribunal on this aspect. Without addressing these aspects, the Tribunal, according to Learned AR, had merely restored the entire proceedings to the file of Learned PCIT to redo the revision proceedings under section 263 of the Act. Per contra, the Learned DR vehemently argued that the Tribunal had passed a reasoned order that the proceedings under section 263 st....