2023 (9) TMI 1708

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.... PER VIKAS AWASTHY, JM: This appeal by 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 a....

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....d. AO amounting to Rs.45,62,270 under section 56(2)(vii)(b) of the Act as income 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 em....

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....ta appearing on behalf of the assessee submitted at the outset that the assessee has filed an application 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....