2024 (9) TMI 1714

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....nt : Shri Sanjit Kumar Das, CIT-DR ORDER Per Bench This appeal filed by the assessee is directed against the order of the National Faceless Appeal Centre, Delhi [CIT(A)] dated 04.03.2023 for Assessment Year (AY)2006-07. 2. At the outset, we note that the assessment was framed u/s. 143(3) r.w.s. 147 of the Income Tax Act, 1961 (the Act) dated 24.11.2011 which was subsequently revised by....

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....arh in ITA No.1359/2010 dated 10.07.2013. Therefore, the AR's argument that there was no error in computation of book profit u/s.115JB of the IT Act, 1961 and the AO had applied his mind has got no force and the same deserved to be rejected and accordingly is rejected." 3. Subsequently, the AO framed assessment u/s 143(3) r.w.s. 263 of the Act vide order dated 24.10.2014 in compliance with ....

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....te that the genesis of the dispute in the case on hand emanates from the order passed by the ld. CIT u/s 263 of the Act which has not been challenged by the assessee. This fact itself transpires that the order passed by the ld. CIT u/s 263 of the Act has reached to the finality and therefore all the proceedings in consequence to the order of the learned CIT u/s 263 of the Act cannot be challenged ....