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2026 Supreme(Online)(ITAT) 11046

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
M/S TIRUPATI BALAJI FIBER LTD. MUZAFFARNAGAR – Appellant
Versus
ITO NEW DELHI – Respondent


ORDER

PER SUDHIR KUMAR, JUDICIAL MEMBER:

This appeal by the assessee is directed against the order dated 11.3.2016 of the Ld.Commissioner of Income Tax (Appeals-9), New Delhi [hereinafter referred to as “Ld.CIT(A))”] pertaining to A.Y. 2007-08.

2. The assessee has raised as many as 19 grounds of appeal, but however, he only argued following the Ground No. 1, 3 & 4 which are interconnected to each other:-

1. That the notice issued u/s. 148 and reassessment proceedings initiated u/s. 147 is bad in law, without jurisdiction and barred by time limitation. The CIT(A) erred in upholding the same.

2. That no notice u/s. 147 r.w.s. 147 of the Act was issued and served on the assessee company, hence, the proceedings u/s. 148 is illegal, without jurisdiction and barred by limitation. The CIT(A) erred in upholding the same.

3. That, the CIT(A) has erred in observing, that, the notice u/s. 148 has been properly served through affixture without appreciating the fact that no notice has ever been issued within time limitation as per the provision of section 149 of the Act.

2. The brief facts relating to the issue are that the proceedings u/s 147 were initiated and after recording the decision and with t

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