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2026 (6) TMI 1515

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....dv. For the Respondent : Sh. Vikram Singh Sharma, CIT, DR ORDER PER ANUBHAV SHARMA, JM: This appeal is preferred by the Assessee against the order dated 18.09.2025 of the Ld. Commissioner of Income Tax (Appeals)-3, Noida (hereinafter referred to as the First Appellate Authority or 'the ld. FAA' for short) in Appeal No: CIT (A), Noida-3/10025/2013-14 arising out of the assessment order ....

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....2023 is made available. Ld. Counsel has submitted that this satisfaction note is not recorded in accordance with law and a consolidated satisfaction note for AY: 2014-15 to 2020-21 has been recorded on the basis of ledger account which shows that in AY: 2014-15 only that there was a debit entry and in subsequent AY: 2015-16, 2016-17 and 2017-18 there was only credit entries in the ledger account. ....

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....r vitiates the entire proceedings. More so, in case like present when what is alleged to be incriminating material is merely a copy of ledger account. Thus, relying the aforesaid proposition of law settled by Hon'ble Delhi High Court in the case of Saksham Commodities Ltd. v. ITO [2024] 161 taxmann.com 485 (Delhi), we are inclined to hold that the assumption of jurisdiction was vitiated and thus, ....