2025 (4) TMI 2424

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....RDER PER SATBEER SINGH GODARA, JM This Revenue's appeal for assessment year 2021-22, 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/250/2023-24/1062290687(1), dated 09.03.2024 involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'....

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.... or, before the date of disposal of appeal." 4. We now advert to the basic relevant facts. A perusal of the Assessing Officer's assessment discussion dated 20.12.2022 indicates that he had himself treated the assessee/respondent as a proprietor of M/s. R.S. Engineering who failed to verify the corresponding purchases of Rs. 16,01,34,945/-. We note with the able assistance coming from the Revenu....