2026 (1) TMI 1687

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....poor, Adv. For the Department : Sh. A.S. Rana, Sr. DR ORDER PER SATBEER SINGH GODARA, JM: This assessee's appeal for assessment year 2016-17, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the "CIT(A)/NFAC"], Delhi's DIN and order no. ITBA/NFAC/S/250/2025-26/1077118505(1), dated 17.06.2025, involving proceedings under sectio....

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....s paper-book at page 9 that she had indeed filed her letter dated 04.01.2022 before the assessing authority seeking to treat the earlier return under section 139(1) as that in response to the reopening herein. This clinching fact has gone unrebutted from the Revenue side. We thus conclude in light of PCIT Vs. Sh. Jai Shiv Shankar Traders Pvt. Ltd. (2016) 383 ITR 448 (Del) that even such a letter r....