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2022 (11) TMI 1429

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..... hna, CA ORDER PER ANADEE NATH MISSHRA, AM: (A) This appeal by Revenue is filed against the order of Learned Commissioner of Income Tax (Appeals)-18, New Delhi ["Ld. CIT(A)", for short], darted 28/08/2020 for Assessment Year 2013-14. The only ground of appeal, as per revised Form-36 filed by Revenue along with letter dated 10/08/2022, is as under: "Whether the Ld. CIT(A) has erred deleting the .....

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..... of Rs.3,95,86,272/-. In doing so, the Ld. CIT(A) followed the earlier orders in assessee's own case, on identical issue, passed by the Ld. CIT(A) for Assessment Years 2011-12 and 2012-13. The present appeal has been filed by the Revenue against the aforesaid impugned appellate order dated 28/08/2020 of the Ld. CIT(A). (A.2) This appeal has been filed by Revenue, on 26/03/2021 which is more than 6 .....

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..... n merits. (A.2.1) In view of the foregoing, and as both sides are in agreement with this, we admit this appeal and proceed to decide the appeal on merits. (B) A paper book containing the following orders of Co-ordinate Bench of ITAT, Delhi passed in assessee's own case, was filed from the assessee's side during the appellate proceedings in Income Tax Appellate Tribunal. (i) Order dated 04/10/2 .....

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..... ntical facts and circumstances, for Assessment Years 2011-12 and 2012-13 respectively. (B.2) At the time of hearing before us, neither side has brought any distinguishing facts and circumstances, or decided precedents, or any legal submissions to our consideration to persuade us to take a view different from the view taken by Co-ordinate Bench of ITAT, Delhi in aforesaid orders dated 04/10/2018 a .....

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