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2022 (5) TMI 513 - AT - Income TaxReopening of assessment u/s 147 - claim of relief under section 54 - delay and non-maintainability of the appeal filed by the assessee - HELD THAT:- Since the assessee has initially preferred an appeal against the reassessment order under section 147 of the Act dated 19.12.2017 against which, the assessee filed an appeal before the ld. CIT(A) and the same was concluded by the ld. CIT(A) vide his order dated 29.06.2018, against which, the appeal filed before the ITAT has also been concluded vide Tribunal's order[2019 (8) TMI 1817 - ITAT CHENNAI] - Since the assessee has again filed another appeal against the original assessment order under section 143(3) of the Act dated 26.03.2013 with a delay of 2002 days by raising the issues already adjudicated in the appeal filed against the order under section 147 of the Act, we are of the opinion that the ld. CIT(A) has correctly dismissed the appeal on both the counts of delay and non-maintainability of the appeal filed by the assessee. We find no reason to interfere with the order passed by the ld. CIT(A). Appeal filed by the assessee is dismissed.
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