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TMI Blog2021 (12) TMI 1492X X X X Extracts X X X X X X X X Extracts X X X X ..... S/Shri R, Venkatraman, Lakshmi Sriram & B. Sivaraman, Advocates For the Respondent : Ms. R. Anita, Addl. CIT ORDER PER DUVVURU RL REDDY, JUDICIAL MEMBER: The cross appeals filed by the assessee as well as Revenue are directed against the order of the ld. Commissioner of Income Tax (Appeals) - 11, Chennai dated 29.02.2016 relevant to the assessment year 2006-07. The assessee has challenged conf ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ect to CIT(A)'s order dated 24.02.2012, the total income was determined as Rs..2,60,29,075/-. The case has been reopened under section 147 of the Act and notice under section 148 of the Act has been issued to the assessee. After considering the submissions of the assessee, the assessment under section 143(3) r.w.s. 147 of the Act was completed by disallowing the excess claim of deduction of Rs..3, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 4. We have heard both the sides, perused the materials available on record and gone through the orders of authorities below. Before us, by filing petition for admission of additional grounds of appeal filed under Rule 11 of Income Tax (Appellate Tribunal) Rules, 1963, the ld. Counsel for the assessee has submitted that the assessee is challenging the legal issue of jurisdiction under section 147 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... The petition filed under Rule 11 of Income Tax (Appellate Tribunal) Rules, 1963 has been admitted. Since the assessee has not raised the legal issue before the ld. CIT(A), we set aside the appellate order and remit the matter back to the file of the ld. CIT(A) to decide the legal issue and thereafter the claim of deductions under section 80IA of the Act, if any, afresh in accordance with law afte ..... X X X X Extracts X X X X X X X X Extracts X X X X
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