Technical infirmity, is of no practical significance if additions on merits cannot be sustained

CA Prarthana Jalan Hon’ble Agra ITAT has in its order of A.C.I.T. vs. Dakshinanchal Vidyut Vitran Nigam Limited has held that Technical infirmity, is of no practical significance if additions on merits cannot be sustained by observing as under:- “As evident from a plain look at the ground of appeal, the actual grievance of the appellant is not on merits but on the legal issue regarding limitations on the powers of the CIT(A) on the ground that post 1st June 2001, it is no longer open to the Commissioners (Appeals) to remit the matter to the file of the Assessing Officer, wherea...