Case Law Details
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 We noted that in the original appeal filed before CIT(A) by the assessee, the assessee has withdrawn his appeal, wherein the grounds was raised on merits i.e., challenging the reopening the assessment and validity of assessment order passed u/s. 143(3) of the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 re-argue the matter but u/s. 154 of the Act. We noted that the limitation prescribed u/s. 154 of the Act is that the mistake can be rectified which is apparent from record and no legal issue or factual issue on merits can be argued or re-argued particularly when the issue is highly debatable. Hence, we cannot entertain this appeal on this short point that this issue being highly debatable as raised before CIT(A). Thus, we dismiss the appeal of the assessee.
FULL TEXT OF THE ORDER OF ITAT CHENNAI
This appeal by the assessee is arising out of the order of Commissioner of Income Tax (Appeals)-3, Chennai in ITA No.177/CIT(A)-3/2018-19 dated 16.12.2019 for Assessment Year 2011-12.
2. The assessee raised the following grounds of appeal:
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