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TMI Blog2023 (4) TMI 1043X X X X Extracts X X X X X X X X Extracts X X X X ..... one year from the end of the assessment year. If any assessment is made for the first time u/s 147 then the assessee cannot be made to pay interest for the period during which it was not possible on the part of the assessee to file return i.e. after one year from the end of the assessment year till issuance of notice u/s 148 of the Act. Hence,order passed by the AO u/s 154 is not in accordance ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Bomaby High Court and Hon ble Jodhpur ITAT Bench referredby assessee. It may pertinent to mention here that ITAT Jodhpur is jurisdictional Bench. 2.1 Apropos solitary ground of the assessee, the facts as emerges from the order of the ld.CIT(A)are as under:- 3.2 I have gone through the order, statement of facts, ground of appeal, written submission, remand report and rejoinder carefully. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dismissed. 2.2 During the course of hearing, the ld.AR of the assessee prayed that the lower authorities have erred in confirming the order passed by the AO u/s 153 of the Act. 2.3 On the other hand, the ld. DR supported the orders of the authorities below. 2.4 We have heard both the parties and perused the materials available on record. It is not imperative to repeat the facts of the cas ..... X X X X Extracts X X X X X X X X Extracts X X X X
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