Generate professional replies to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
Step 1 – Issue Identification & Review
The AI analyses your query, notice, order, or uploaded documents and identifies the key issues involved.
• Review the issues identified by the AI • Add, edit, remove, or refine issues as required
Step 2 – Draft Generation
Once you approve the issues, the AI performs issue-wise legal research and prepares a structured draft response.
• Relevant statutory provisions • Judicial precedents and Supreme Court, High Court and other citations • Issue-wise legal analysis • Practical arguments and supporting content • Professionally structured draft ready for further review.
Appeal Dismissed: Section 154 Order Cannot Challenge Section 143(3) Assessment The tribunal dismissed the appeal filed by the assessee against the order passed under section 154 by the Assessing Officer. The tribunal clarified that ...
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Appeal Dismissed: Section 154 Order Cannot Challenge Section 143(3) Assessment
The tribunal dismissed the appeal filed by the assessee against the order passed under section 154 by the Assessing Officer. The tribunal clarified that the appeal was solely related to the order passed under section 154 and did not pertain to the earlier assessment order passed under section 143(3). Since the appellant had not challenged the assessment order, the appeal was dismissed.
Issues: Appeal against order of National Faceless Appeal Centre for assessment year 2017-18.
Analysis: The appeal was filed by the assessee against the order of the National Faceless Appeal Centre, Delhi, dated 21.03.2022 for the assessment year 2017-18. The appellant, an individual engaged in the business of civil contractors and builders, had filed the Return of Income declaring a total income of Rs.124,94,87,852 for the said assessment year. The assessment was completed by the Assessing Officer under section 143(3) of the Income Tax Act, 1961, at a total income of Rs.125,07,76,100 after certain disallowances. Subsequently, the Assessing Officer enhanced the disallowance under section 14A by a further amount. An appeal was filed against this order before the NFAC, which confirmed the action of the Assessing Officer.
The appellant challenged the order passed under section 154 by the Assessing Officer, and the appeal before the tribunal was specifically against this order. It was noted that the appellant had not challenged the assessment order passed under section 143(3) dated 28.08.2019. The tribunal observed that the grounds of appeal filed by the assessee were solely against the order passed under section 154, which was rightly dismissed by the NFAC. Consequently, the tribunal dismissed the appeal filed by the assessee.
In conclusion, the tribunal dismissed the appeal filed by the assessee against the order passed under section 154 by the Assessing Officer. The tribunal clarified that the issue raised in the appeal did not pertain to the assessment order passed earlier under section 143(3). The grounds of appeal were solely related to the order passed under section 154, and since the appellant had not challenged the assessment order, the appeal was dismissed.
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