2023 (5) TMI 1477

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....Barman, Addl. CIT-DR ORDER PER SANJAY GARG, JUDICIAL MEMBER: Both the appeals have been preferred by the assessee against the separate orders dated 19.09.2022 of the National Faceless Appeal Centre [hereinafter referred to as the 'CIT(A)'] passed u/s 250 of the Income Tax Act (hereinafter referred to as the 'Act'). Since, common issues are involved in both the appeals, hence these have he....

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.... the CIT(A) is required to be treated within the limitation period as the same was covered by the decision of the Hon'ble Supreme Court in Suo moto Writ Petition (C) No. 3 of 2020 dated 10.01.2022. The ld. Counsel for the assessee has further submitted that the assessee has filed rectification application which has been dismissed by the Assessing Officer in a mechanical manner. The assessee inadve....