There were two different search and seizure actions conducted by the Department and the assessee’s case was reopened twice for each year under consideration. The Ld. CIT(A) passed a combined order, allowing all the appeals filed before it. The Department filed one appeal for each assessment year under consideration. It was held that each assessment order is separate and separate appeals have to be filed for each assessment order. Appeal dismissed as defective. (ITA 1695-97 of 2022 dated January 30, 2023) ( AY. 2009 -10 , to 2011 -12 )
ACIT v. Ajit Anantrao Pawar (Mum)(Trib) www.itatonline .org
S. 253: Appellate Tribunal – Maintainability – Consolidated order of CIT(A) for more than one year – One appeal cannot be filed against two reassessment orders for the same assessment year- Income-tax Appellate Tribunal Rules, 1963 –R. 9 -Appeal of revenue was dismissed . [ S. 132, 153C ,ITAT R, 9 ]