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INCOME TAX APPELLATE TRIBUNAL (CHENNAI BENCH)
MANU KUMAR GIRI, JM
KUMARESAN BHAGAVATHIPERUMAL PILLAI KANYAKUMARI – Appellant
Versus
THE INCOME TAX OFFICER INTERNATIONAL TAXATION WARD TUTICORIN – Respondent
| Table of Content |
|---|
| 1. appeal admission and process (Para 1 , 2) |
| 2. jurisdiction and procedural adherence (Para 3 , 4 , 5) |
| 3. precedent not following proper procedures (Para 6 , 7 , 8) |
| 4. doctrine of merger and appeal processes (Para 9 , 10 , 11) |
| 5. final judgment and order outcomes (Para 12 , 14) |
| 6. final decision issuance (Para 15 , 16) |
आदेश/ORDER
PER MANU KUMAR GIRI, JM:
This is an appeal preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeals) Chennai-16, (hereinafter in short ‘the Ld.CIT(A)’), dated 31.07.2024 for the Assessment Year (hereinafter in short ‘AY’) 2018-19.
2. The registry has noted delay of ‘224’ days in filing the appeal. Considering the period of delay and reasons pleaded, we condone the delay and admit the appeal for adjudication.
3. At the outset, the Ld. Counsel for the assessee has raised an additional ground relating to jurisdiction of Jurisdictional Assessing Officer (‘JAO’) in the light of the CBDT Notification dated 29.03.2022. The Ld.DR, Ms. Gauthami Manivasagam, JCIT, objected admission of additional ground raised by the assessee.
4. We have heard admission of legal issue and found any substance in the submissions of the Ld. Co
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