2025 (4) TMI 2133

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....nbsp;Ms.Gowthami Manivasagam, JCIT ORDER PER AMITABH SHUKLA, A.M : This appeal is filed by the assessee against the order bearing DIN & Order No.ITBA / NFAC / S / 250 / 2024-25 / 1072191979(1) dated 15.01.2025 of the Learned Commissioner of Income Tax [herein after "CIT(A), National Faceless Appeal Center[NFAC], Delhi, for the assessment years 2012-13. 2.0 At the outset, Ld.Counsel for....

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.... 4.0 We have heard rival submissions in the light of material available on records. There is no denying the fact that the addition has been made by the Ld.AO for non-compliance by the assessee. It is also seen that the Ld.CIT(A) has merely rejected the additional evidences for non-reference to Rule 46A by the assessee. It is trite law that substance prevails over Form. Non-mention of Rule 46A c....