2020 (8) TMI 662

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.... 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 case. 3. Heard both parties and perused the....

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....ce 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 conceded that if this Tribunal remand the matter to....