2023 (1) TMI 471

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....ard to the facts and circumstances of the case, the Hon'ble Commissioner of Income Tax (Appeals) has erred in law and on facts in dismissing the appeal of the assessee company wholly on untenable grounds. 2. That on the facts and in law, the Hon'ble Commissioner of Income Tax (Appeals) has erred in holding that the order dated 19/06/2019 passed by the Assessing Officer u/s 143(3) r.w.s.263 of the Act, is not appealable before the CIT(A). 3. That on the facts and circumstances of the case, the learned CIT(A) was not justified in confirming the addition of Rs.6,35,58,558/- on account of Anticipated Loss. 4. That the appellant craves leave to add, alter, amend, change, vary substitute or raised any additional ground of appeal if it come ....

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.... Indore Pvt. Ltd. vs. PCIT, the aforesaid revisionary order dated 14/03/2019 of PCIT was quashed; thus in effect, restoring the original assessment order dated 27/12/2016 passed by the Assessing Officer. The present appeal before us has been filed by the assessee against the aforesaid impugned appellate order dated 04/02/2020 of the learned CIT(A). In the course of appellate proceedings in Income Tax Appellate Tribunal, a copy of aforesaid order dated 07/09/2022 of Co-ordinate Bench of ITAT in the case of DLF Garden City Indore Pvt. Ltd. vs. PCIT in ITA No.3731/Del/2019 for AY 2014-15 was filed from the assessee's side. (A.1.1) At the time of hearing before us, Mr. R.S. Singhvi, CA, the learned Authorized Representative ('AR', for short) f....