9911796707
TMI Blog2024 (5) TMI 1017X X X X Extracts X X X X X X X X Extracts X X X X ..... ) while passing the order, did not deal with the specific ground raised by the assessee regarding the rectification order passed by the CPC u/s 154 of the Act, which is bad in law, since rectification order itself lacks jurisdiction being passed without issuance of original intimation u/s. 143(1) of the Act. Thus we are of the view that a fresh opportunity should be given to the assessee and, acco ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ommissioner of Income Tax (Appeals)-National Faceless Appeal Centre (NFAC), Delhi ( Ld. CIT(A) ), relating to the assessment year (AY) 2020-21. 2. The grounds raised by the assessee, reads as under: 1. On the facts and in the circumstances of the case the order of the commissioner(appeals) affirming the rectification order passed by the Centralised Processing Centre CPC-Bangalore/ Assessing Office ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e order passed by the Assessing Officer. 4. For these and other grounds that may be urged at the time of hearing, appellant prays that the Hon'ble Tribunal may be pleased to delete the arbitrary addition made by the CPC- Bangalore since the issue falls outside the ken of 'prima facie adjustments'. 3. Brief facts of the case as culled out from the record are that the assessee is a compa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s now in appeal before the Tribunal, raising as many as four grounds. 6. At the time of arguments, the learned AR pressed only Ground No.1 and submitted that the Ld.CIT(A) while passing the order, did not deal with the specific ground raised by the assessee regarding the rectification order passed by the CPC u/s 154 of the Act, which is bad in law since rectification order itself lacks jurisdictio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that a fresh opportunity should be given to the assessee and, accordingly, we set aside the impugned order and restore the issue to the file of the Ld. CIT(A) with a direction to adjudicate the grounds of the assessee regarding the legality of the rectification order passed by the CPC u/s 154 of the Act, without issuance of original intimation u/s 143(1) of the Act, after affording the opportunit ..... X X X X Extracts X X X X X X X X Extracts X X X X
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