TMI Blog2022 (11) TMI 1206X X X X Extracts X X X X X X X X Extracts X X X X ..... addition made in respect of dividend income received from investment in units of mutual funds u/s. 115BBDA of the Act. We note that since the assessment order u/s. 143(3) of the Act has already been passed in the present case before us, the intimation u/s. 143(1) of the Act against which the assessee is in appeal before us got merged with the aforesaid assessment order. Once the present intimation u/s. 143(1) of the Act having got merged in the assessment order passed u/s. 143(3) of the Act, the cause of action for the present appeal itself has vanquished, rendering the instant appeal as infructuous. We have not expressed any views in respect of the matter raised in the assessment order passed u/s. 143(3) of the Act for which appeal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... it Petition (C) No. 3 of 2020 dated 10.01.2022 by which the period from 15.03.2020 to 28.02.2022 has been directed to be excluded for the purpose of limitation. Vide this order a further period of 90 days has been granted for providing the limitation from 01.03.2022. Accordingly, we condone the delay and proceed to adjudicate upon the matter. 3. Grounds raised by the assessee are reproduced as under: General 1. erred in confirming the action of Ld. AO in computing total income of the Appellant at Rs. 41,55,30,701 as against income of Rs. 41,15,79,882 offered to tax by the Appellant in Revised Return of Income for the subject assessment year; CIT(A) Order is bad in law: 2. erred in not adjudicating on grounds ra ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... der Section 234B of the Act 7. erred in levying interest under Section 234B of the Act of Rs. 1,76,36,982; Levy of interest under Section 234C of the Act 8. erred in levying interest under Section 234C of the Act of Rs. 26,17,929; The Appellant craves leave to add, alter, vary, omit, substitute or amend the above grounds of appeal, at any time before or at, the time of hearing of the appeal, so as to enable the Learned Hon'ble ITAT to decide this appeal according to law. 4. Brief facts of the case are that return was file d on 30.10.2017 reporting total income of Rs.41,15,79,882/- which was processed by the Central Processing Unit (CPC), Bengaluru u/s. 143(1) of the Act at total taxable income of Rs.41,55,30,7 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... A of the Act. We note that since the assessment order u/s. 143(3) of the Act has already been passed in the present case before us, the intimation u/s. 143(1) of the Act against which the assessee is in appeal before us got merged with the aforesaid assessment order. Once the present intimation u/s. 143(1) of the Act having got merged in the assessment order passed u/s. 143(3) of the Act, the cause of action for the present appeal itself has vanquished, rendering the instant appeal as infructuous. While doing so, we would make it very clear that we have not expressed any views in respect of the matter raised in the assessment order passed u/s. 143(3) of the Act for which appeal by the assessee before the Ld. CIT(A) is pending for adjudicati ..... X X X X Extracts X X X X X X X X Extracts X X X X
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