2025 (7) TMI 303

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....7 dated 24.10.2024, which has been passed against the assessment order u/s 143(3) of the Act, dated 28.12.2018. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: "1. That on the facts and in the circumstances of the case, Ld. Commissioner of Income Tax (Appeals) National Faceless Appeal Centre (NFAC) [here-in-after referred to as Ld. CIT(Appeals)] was not justified and grossly erred in treating the appeal filed by the appellant as withdrawn for the second time based on incorrect assumption of facts. 2. That on the facts and in the circumstances of the case, Ld. CIT(Appeals) was not justified and grossly erred in disposing off the appeal disregarding the specific direction of the H....

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....in-above, either before or at the time of hearing of this appeal." 3. Brief facts of the case are that the assessee is Category-II Alternative Investment Fund registered with SEBI and had filed its return of income for AY 2016-17 showing total income of Rs. 21,12,430/-. The Assessing Officer (hereinafter referred to as Ld. 'AO') added the undisclosed interest income of Rs. 28,13,53,763/- to the total income of the assessee and assessed the total income at Rs. 28,34,65,193/- u/s 143(3) of the Act. Aggrieved with the assessment order, the assessee filed an appeal before the Ld. CIT(A) who has merely mentioned in the appeal order that "As Form 5 has been issued on 03.01.2022, the assessee is allowed to withdraw the appeal." Aggrieve....