2025 (3) TMI 1890

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.... ORDER PER PRADIP KUMAR KEDIA, AM: The assessee preferred the captioned appeal, challenging the order dated 02.08.2017 passed by the Commissioner of Income Tax (Appeals)-37, New Delhi (in short "CIT(A)") Delhi pertaining to Assessment year 2014-15 and arises out of the assessment order dated 19.12.2016 passed under s. 143(3) of the Income Tax Act, 1961 (in short "The Act"). 2. When the ....

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....e assessee which stand at Rs. 4,66,89,899/- and thus stands reconciled with the opening balance of the assessment year 2014-15 under appeal. 3. The very issue has been examined by the AO on substantive basis in the preceding assessment year 2012-13 and, therefore, the additions on protective basis and that too, in a different assessment year, do not survive any more. 4. The Ld. Counsel thus ....

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....3-14. The issue thus stand resolved by the assessment order framed for A.Y. 2013-14. The reassessment order for AY 2013-14 was framed subsequent to impugned First Appellate order under challenge. Thus, the Ld. CIT(A) was not in a position to take cognizance of such facts. We thus find sufficient basis in the plea of the assessee for cancellation of the protective additions in so far as assessment ....