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TMI Blog2023 (4) TMI 1379X X X X Extracts X X X X X X X X Extracts X X X X ..... Revenue : Shri Suhas Kulkarni, IRS-Addl.CIT. ORDER PER BENCH : These six appeals filed by the one Assessee are directed against the separate orders of ld. Commissioner of Income Tax(Appeals)[NFAC], Delhi, all dated 16.02.2023. These six appeals were heard together and decided by common order as the issue involved is same in both the quantum appeals. Therefore, for the sake of convenience we ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e period prior to 01st June, 2015." Brief facts of the case : 2. The relevant paragraph of the order of the Ld. Commissioner of Income Tax (NFAC) is reproduced here as under : "It is seen from the Form-35 that the appellant mentioned the order appealed against as 200A. However, no such order was enclosed to Form-35. A letter of ITO (TDS-2) Pune vide PN/ITO(TDS2)/Outstanding demand/2021-22/19 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on 200A before the ld. CIT(A). The ld.AR admitted that assessee had filed an appeal against letter of the AO and justification report, downloaded from the systems. The ld.AR also admitted before us that he has not filed any copy of order under section 200A either before the ld. CIT(A) or before the Hon'ble ITAT. The ld.AR admitted that he has merely filed copy of the justification report downloade ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (A)'s observations regarding merits of the case are outside the scope of the order. We do not intend to comment on the merits of the case. 3. Accordingly, Ground No. 1 of the assessee is dismissed. Ground No. 2 : 4. Ground No. 2 is regarding the merits of the case. No order under section 200A has been filed before us. No order under section 200A was filed before the ld. CIT(A). ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... milar facts are involved in these appeal of the assessee, hence, our observations made in ITA No's. 228/PUN/2023 for A.Y.2014-15 - 26Q for Q1 shall apply mutatis mutandis to these five appeals also. Accordingly, grounds of appeal raised by the assessee are dismissed. 8. In the result, appeals of the Assessee in ITA No's. 229 to 233/PUN/2023 are Dismissed. 9. To sum up, all the Six Appeals filed ..... X X X X Extracts X X X X X X X X Extracts X X X X
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