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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
N.K. Billaiah, ACJ, Yogesh Kumar U.S, J
Simbhaoli Power Pvt Ltd – Appellant
Versus
Pr. C.I.T – Respondent
| Table of Content |
|---|
| 1. overview of appeals and jurisdiction. (Para 1 , 2 , 4) |
| 2. background facts and representation. (Para 3 , 5 , 11) |
| 3. assessment of the pcit's jurisdiction and reasoning. (Para 12 , 14 , 16) |
| 4. final ruling and directions on the assessment order. (Para 20 , 22) |
ORDER
PER N.K. BILLAIYA, ACCOUNTANT MEMBER:-
The above captioned two separate appeals by the assessee are preferred against two separate orders of the PCIT, Ghaziabad and Meerut dated 22.03.2019 and 08.03.2021 pertaining to A.Ys. 2014-15 and 2015-16.
2. In both these appeals, the assessee has challenged the assumption of jurisdiction u/s 263 of the Income-tax Act, 1961 [the Act, for short] by the respective PCITs in respective A.Ys.
3. Since the underlying facts in the issues are identical in both these appeals, they were heard together and are disposed of by this common order for the sake of convenience and brevity.
4. Representatives of both the sides agreed to address the bench on the facts of ITA No. 4620/DEL/2019 for A.Y 2014-15.
5. Representatives of both the sides were heard at length. Case records carefully perused. Relevant documentary evidence brought on record duly considered in light of Rule 18(6) of t
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