2023 (9) TMI 1708

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....the assessee is directed against the assessment order dated 10/01/2023 passed u/s. 147 r.w.s. 144C(13) of the Income Tax Act, 1961 [ in short 'the Act], for assessment year 2014-15. 2. The assessee has raised following grounds in appeal: " The following grounds are independent of and without prejudice to one another: 1. On the facts and circumstances of the case and in the law, the final asse....

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....e from other sources and has also erred in invoking the amended provisions of section 56(2)(vii)(b)(ii) of the Act for years prior to AY 2014-15. 3. On the facts and circumstances of the case and in law, the Hon'ble DRP has grossly erred in completely ignoring and not considering the submissions made via email dated 13 December, 2022 wherein the Appellant had submitted the write up for grant....

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....ion before the Dispute Resolution Panel(DRP) under Rule 13 of Income Tax (Dispute Resolution Panel) Rules, 2009 for rectification of the Directions on 23/12/2022. If the aforesaid application is allowed, the present appeal of the assessee would become infructuous. The ld. Authorized Representative of the assessee furnished copy of the said application and prayed that the DRP may be directed to dec....