2014 (1) TMI 139

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..... around the completion of assessment subsequent to disposal of an application filed by the appellant assessee under Section 245C by the Settlement Commission at Chennai. Original assessment came to be completed under Section 143(3) of the Income Tax Act on 28.03.1988 so far as this particular assessment year. Meanwhile, Settlement Commission after admitting the application filed by the assessee se .....

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..... smissed the appeal considering the grievance of the appellant assessee with regard to levying interest under Section 220(2) in a detailed discussion at paragraph 5 of the order of Commissioner of Income Tax(Appeals). This order came to be challenged before the Appellate Tribunal raising several grounds. However, without touching the merits of the orders passed by the Commissioner of Income Tax(App .....

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..... her of the said sections;" 5. It is very clear from reading of the above provision that the assessee, aggrieved by an order made under Section 154, can file appeal only before Commissioner of Income Tax (Appeals) which the appellant assessee has adopted in the above case and the Commissioner of Income Tax(Appeals) has also considered the appeal on merits and disposed of the same as indicated abov .....

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