In the result, the revenue appeals in ITA Nos
Bench: Dr. Mitha Lal Meena, Hon'Ble & Anikesh Banerjee, Hon'Ble
reassessment proceedings u/s 148, but the same was allowed by the NFAC/CIT(A) without appreciating the facts. The Ld. CIT (DR) contended that the AO disallowed such claim of the assessee on the ground that the report which was required to be submitted online was submitted late and therefore the mandatory condition of the section was not satisfied