2025 (7) TMI 25

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ri.Arun Raj S, Advocate For the Respondent : Sri.Sundarasan S, CIT-DR ORDER PER PRAKASH CHAND YADAV, JM : Both these appeals relating to same assessee, however, pertain to different assessment years are decided by way of this consolidated order for the sake of convenience. ITA No.373/Coch/2024 : Asst.Year 2015-2016 2. The brief facts of the case as coming out from the orders of t....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....d Counsel for the assessee inter alia argued that it is a case where sec.263 has been invoked after the completion of assessment u/s. 153A of the Act. It is the contention of the learned Counsel for the assessee that in cases where assessments are completed u/s. 153A of the Act, an approval from the JCIT has to be obtained by the concerned AO, and unless and until it is shown that the said approva....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... Court in the case of CIT(E) v. Love in Action Society reported in (2022) 442 ITR 358 (Ker.). Respectfully following the verdict of the Hon'ble jurisdictional High Court, cited supra, we restore this matter to the file of the PCIT and give liberty to the assessee for raising all its legal contentions before the PCIT. 6. In the result, the appeal filed by the assessee is allowed for statistical ....