2025 (4) TMI 1935

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....the Department : Shri Ashish Tripathi, Sr. DR ORDER PER VIMAL KUMAR, JUDICIAL MEMBER: The appeal filed by the appellant/assessee is against order dated 12.03.2024 passed by Learned Commissioner of Income- Tax(Appeals), Vadodara (hereinafter referred as 'Ld. CIT(A)') under Sections 250 of the Income-Tax Act, 1961 (hereinafter referred as "the Act") arising out of assessment order dated 19.....

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....appellant/assessee preferred present appeal with following grounds: "Ground no 1 Ld. CPC has erred in law and facts of the case while rejecting the rectification filed by the assessee on 22.04.2020. Ground no 2 Ld. CIT(A) has erred in law and facts of the case in upholding the addition of Rs. 6.44,42,606/- and 79,21,952/- made by the Ld. CPC under section 43B of....

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.... no 5 The assessee may please be allowed the right to add/delete/modify any of the grounds of appeal at any stage." 5. At the time of hearing, Learned Authorised Representative for the appellant/assessee submitted that the ACIT, Circle-1(1), Delhi in letter dated 24.05.2024 has mentioned as under:- "Order pursuant to Hon'ble Delhi HC ORDER for AY 2017-18, 2018-19 & 2019-20....

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.... "Effective date means 15 days from the date of receipt of the Hon'ble NCLT order by the resolution applicant" Thus, effective date is 17.04.2019. Therefore, all the payables and receivables of the assessee of the periods prior to the effective date have been taken into account while creating dues in the resolution plan which stands extinguished as per the plan. Therefore, refunds of....