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147 r.w.s 144C(13) of the Income Tax Act, 1961 dated 23.12.2024 for the A.Y.2018-19, emanating from the order of the Dispute Resolution Panel u/s.144C(5) of the Act, dated 20.12.2024. The Assessee has raised the following grounds of appeal : ITA No.147/PUN/2025 [A] “1. On the facts and in the circumstances of the case