2024 (3) TMI 1480

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....spondent : Mr. Arvind Kumar, Adv. ORDER CM APPL. 22753/2021(Delay of 74 days in filing) & CM APPL. 22754/2021 (Delay of 266 days in Re-filing) 1. These applications are filed on behalf of the appellant seeking condonation of 74 days' delay in filing and 266 days' delay in refiling the present appeal. 2. Bearing in the mind the disclosures made, the delay of 74 days in filing the appeal....

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....x Appellate Tribunal was justified in the eye of law and in the facts and circumstances of the present case, in holding the assessment-order being illegal, because it has been passed by the Assessing Officer without assuming valid jurisdiction as the case of the assessee was transferred to the Assessing Officer without passing an order under-section 120 of the Income Tax Act, 1961? (3)Whe....

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....has essentially addressed submissions on the ambit of Section 124(3) of the Income Tax Act, 1961 ["Act"] to contend that since the respondent-assessee had failed to raise any question with respect to the jurisdiction of the Assessing Officer ["AO"] in accordance with the provisions made in Section 124(3) of the Act, it would clearly not amount to an illegality nor would it lead to irreversible con....