Assessment order was completed u\/s 144 of the Act by making an addition of Rs. 20,70,000\/- along with demand notice raising demand of Rs. 1,03,62,001\/-. In the computation sheet gross total income was considered at Rs. 82,80,000\/-. An assessee filed an appeal against the said order before CIT(A). The assessee has also filed an application u\/s 154 of the Act pointing the mistake apparent from record in the computation sheet enclosed along with the demand notice. The AO has passed order u\/s 154 on 11.02.2020 and reduced the income by Rs. 62,10,000\/- and raised the revised demand of Rs. 25,90,455\/-. On receipt of rectification order, the AR of the assessee advised him to withdrawn an appeal filed against original order passed u\/s 144 by making an application on 19.08.2020. Accordingly, CIT(A) has passed the order allowing withdrawal request of assessee on 20.08.2020.<\/p>\n
Meanwhile, as per the AR’s advice, assessee has filed an appeal against the order passed u\/s 154 wherein the ground has been raised that Ld AO erred in making addition of Rs. 20,70,000\/- as undisclosed income u\/s 69 of the Act.<\/p>\n
In this background, whether –<\/p>\n
(a) Assessee can context the addition of Rs. 20,70,000\/- made in the assessment order u\/s 144 in an appeal filed against order u\/s 154 of the Act?<\/p>\n
(b) Assessee can file an appeal against an order passed u\/s 144 of the Act with delay condonation once again?<\/p>\n
(c) Assessee can file a petition u\/s 264 of the Act against the order passed u\/s 144 on 08.12.2019 since he can file within one year from the date of receipt and due to the covid period limitation is extended?<\/p>\n
Kindly guide!<\/p>\n","protected":false},"comment_status":"open","ping_status":"closed","template":"","qa_expert":[139],"qa_category":[23],"qa_tag":[123,378,377],"class_list":["post-22205","qa","type-qa","status-publish","hentry","qa_expert-research-team","qa_category-income-tax","qa_tag-appeal","qa_tag-order-passed-u-s-144","qa_tag-withdrawal-of-appeal-before-cit-a"],"acf":[],"jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/qa\/22205","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/qa"}],"about":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/types\/qa"}],"replies":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/comments?post=22205"}],"wp:attachment":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/media?parent=22205"}],"wp:term":[{"taxonomy":"qa_expert","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/qa_expert?post=22205"},{"taxonomy":"qa_category","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/qa_category?post=22205"},{"taxonomy":"qa_tag","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/qa_tag?post=22205"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}