2020 (8) TMI 662

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.... ORDER PER S.S. VISWANETHRA RAVI, JM : This appeal by the assessee against the order dated 02-01-2017 passed by the Commissioner of Income Tax (Appeals)-7, Pune ["CIT(A)‟] for assessment year 2009-10. 2. The only issue is to be decided is as to whether the CIT(A) justified in confirming the addition made by the AO u/s. 154 of the Act proceedings in the facts and circumstances of the....

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..... Further, he submits that there was no reference to this issue nor any discussion made by the AO in the original order passed u/s. 143(3) of the Act. He submits that when there is no reference or discussion in the assessment proceedings the order u/s. 154 does not lie. On perusal of the record, we find that the contentions made before us by the ld. AR were not raised before the AO and fairly conc....