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TMI Blog2017 (7) TMI 1283X X X X Extracts X X X X X X X X Extracts X X X X ..... und extracted in the order and has been reproduced in the earlier part of this order. The said argument has been addressed though for explaining the delay in filing of the appeal. I find that the finding of the CIT(A) that it was a general ground, cannot be faulted with. Since the assessee seeks to assail the jurisdiction of the AO itself by way of facts available on record,find that in the pec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... na,CA Respondent by : Shri Manj it Singh, Sr.DR ORDER The present appeal has been filed by the assessee assailing the correctness of the order dated 20.02.2017 of CIT (Appeals)-2 Chandigarh pertaining to 2009-10 assessment year on various grounds on merits. However, attention was invited to ground No. 1, which, it was submitted has been left undecided by the CIT(A) despite the fact t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on the demand notice. 3 Referring to the impugned order, he submitted that however, while deciding the appeal, he failed to address the said ground. 4. The ld. Sr. DR considering the record submitted that the said submission was advanced and considered for condoning the delay of 1355 days and in the absence of any specific prayer, the CIT(A) has dismissed ground No. 1 as a general ground. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ith law requiring the assessee first to raise specific objection to the jurisdiction of the AO and only thereafter the assessee can pray for a decision on merits, if need be. Said order was pronounced after hearing the submissions of the parties before the Bench. The jurisdictional ground being the foundational ground can be assailed at any stage, specially where the facts are already available on ..... X X X X Extracts X X X X X X X X Extracts X X X X
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