Section 154- No legal or factual issue on merits can be argued or re-argued if issue is highly debatable

Raymold Lighting Pvt. Ltd. Vs ITO (ITAT Chennai) ITAT noted that this appeal is against the rectification order passed by A.O and the impugned order by CIT(A) on this order of rectification u/s. 154 of the Act dated 27.09.2017. We noted that in the original appeal filed before CIT(A) by the assessee, the assessee has withdrawn his appeal, wherein the grounds was raised on merits i.e., challenging the reopening the assessment and validity of assessment order passed u/s. 143(3) of the Act. The CIT(A) in the impugned order has reproduced the grounds which clearly shows that the assessee want to r...