High Court directs ITSC reconsideration impacting AO's jurisdiction. Tribunal deems appeals infructuous.

The Tribunal allowed all appeals filed by the assessee, holding the assessment orders as infructuous due to the High Court's direction to the ITSC. The High Court quashed the ITSC's orders and directed reconsideration of the assessee's applications, impacting the jurisdiction of the AO's assessment orders. Consequently, the Tribunal deemed the appeals against the assessment orders as infructuous.

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Issues:
Challenging order dated 19.2.2015 by CIT(A) for Assessment Years 2008-09, 2009-10, 2010-11, and 2011-12.
Validity of assessment orders passed by AO following rejection of settlement application by ITSC.
Impact of High Court's order dated 9.10.2017 on assessment orders.
Jurisdiction of AO to proceed with assessment post rejection of settlement application by ITSC.
Infructuous nature of impugned orders post High Court's direction to ITSC.

Analysis:

Issue 1: Challenging CIT(A) Order
The appeals were filed by the assessee against the order dated 19.2.2015 by CIT(A) for the Assessment Years 2008-09, 2009-10, 2010-11, and 2011-12. The CIT(A) upheld the assessment order passed by the AO. The assessee challenged these orders through the appeals.

Issue 2: Validity of Assessment Orders
Following the rejection of the settlement application by the ITSC, the AO issued notice for assessment under different sections of the Income-tax Act for various assessment years. The High Court, through interim orders, directed the assessment proceedings to continue. The AO subsequently passed assessment orders, which were challenged by the assessee before CIT(A).

Issue 3: Impact of High Court's Order
The High Court, through an order dated 9.10.2017, quashed the orders passed by the ITSC and directed it to proceed with the applications filed by the assessee. The assessee intended to raise an additional ground challenging the jurisdiction of the assessment orders in light of this High Court order.

Issue 4: Jurisdiction of AO
The contention was raised regarding the jurisdiction of the AO to pass the assessment orders post the rejection of the settlement application by the ITSC. The High Court's interim directions allowed the assessment proceedings to continue, and the AO proceeded with passing the orders.

Issue 5: Infructuous Nature of Orders
Considering the High Court's direction to the ITSC to proceed with the matter and reconsider the applications filed by the assessee, the Tribunal concluded that the assessment orders had become infructuous. The jurisdiction now vested with the ITSC, making the appeals against the impugned orders also infructuous.

In conclusion, the Tribunal allowed all the appeals filed by the assessee, holding the impugned orders as infructuous due to the High Court's direction to the ITSC, which impacted the jurisdiction of the assessment orders passed by the AO.

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