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2025 Supreme(Online)(ITAT) 6772

INCOME TAX APPELLATE TRIBUNAL (JAIPUR BENCH)
DR. S. SEETHALAKSHMI, JM, SHRI RATHOD KAMLESH JAYANTBHAI, AM
Maya Kumari – Appellant
Versus
The ITO – Respondent


Advocates:
For the Appellants/Petitioners: Shri Shrawan Kumar Gupta, Adv.
For the Respondents: Shri Gautam Singh Choudhary, Addl. CIT

ORDER

PER: DR. S. SEETHALAKSHMI, J.M.

This is an appeal filed by the assessee against the order of ld. CIT(A), National Faceless Appeal Centre (NFAC) Delhi dated 04.10.2023 passed under section 250 of the I.T. Act, 1961, for the assessment year 2012-13.

2. The assessee has raised the following grounds of appeal :-

“1.1 The impugned order u/s 147 rws 144 of the I.T. Act, 1961 dated 04.12.2019 as well as the notice u/s 148 and action or proceedings u/s 147/148 are illegal, bad in law, barred by limitation, without jurisdiction, without approval/satisfaction from the proper or competent authority, against the principle of natural justice and various other reasons or and further contrary to the real facts of the case hence the same may kindly be quashed.

1.2 The ld. AO has grossly erred in law as well as on the facts of the case in passing the Ex-party order without providing the adequate and reasonable opportunity of being heard to the assessee and without considering the material and details in gross breach of law and are bad in law, invalid, illegal and on facts of the case, and hence the same may kindly be quashed and the resultant addition may kindly be deleted in full.

2. The ld. CIT (

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