2016 (12) TMI 1626

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....ibunal in so rejecting the appeal as time barred. Their Lordships were of the considered view that it was a fit case for condonation of delay by the Tribunal. Accordingly, the delay was condoned and the matter was remitted to the Tribunal for adjudication on merits. That is how we have come to be in seisin of the matter once again. 2. This appeal challenges learned CIT(A)'s order dated 27th July, 2007, in the matter of order under section 154 r.w.s. 143(1A) of the Income Tax Act, 1961, for the assessment year 1991-92. Grievance raised by the assessee is as follows :- "The learned Commissioner of Income Tax (Appeals) erred in law and facts has upheld the order dated 19.08.1994 passed by the Assessing Officer under section 154 of ....

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....l tax on the basis of orders u/s. 250 by the CIT(A) would be given immediately on receipt of such orders. The contention put forth by the assessee in reply to notice u/s.154 have already been dealt with by the Assessing Officer in assessment order u/s. 143(3). The further levy of additional tax of Rs. 59,97,41,165/- is, therefore, ordered." 4. Aggrieved, assessee carried the matter in appeal before the learned CIT(A) but without any success. The assessee carried the matter further in appeal to the Tribunal but the matter was again remitted to the file of the learned CIT(A) for fresh adjudication by a speaking order. The assessee did not succeed in this round either. Once again, the assessee is in appeal before us. 5. We have heard the....