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TMI Blog2023 (12) TMI 1368X X X X Extracts X X X X X X X X Extracts X X X X ..... ment : Sh. Ashish Mohanty, CIT- DR ORDER PER M. BALAGANESH, AM: Both the appeals filed by Assessee arise out of the orders of the Learned Commissioner of Income Tax (Appeals)-38, Delhi [hereinafter referred to as 'Ld. CIT(A)'] dated 28/01/2020 and 13/02/2020 for Assessment Year 2011-12. 2. As identical issue is involved in both the appeals, hence, they are taken up together and disposed of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that the assessee had fully filed its TDS returns with the Income Tax Department in the prescribed form within the prescribed time for the AY 2011-12. The assessments on those TDS returns were framed in the present proceedings by the Ld. AO on 28/12/2017 for the AY 2011-12. The preliminary objection raised by the assessee is that the said assessment framed on 28/12/2017 is barred by limitation in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ubjected to any revision proceedings u/s 263 of the Act by the Ld. PCIT. While this is so, there is absolutely no need for the Revenue to have framed yet another assessment on 28/12/2017 for AY 2011-12 by taking a divergent stand with regard to applicability of TDS on lease rent paid to NOIDA. When this fact was brought to the notice of the Ld. CIT(A), the Ld. CIT(A) did not even bother to give an ..... X X X X Extracts X X X X X X X X Extracts X X X X
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