ORDER

PER KRINWANT SAHAY, AM,

These three appeals are filed by the Assessee challenging the Final Assessment Orders passed u/s 143(3) r.w.s. 144C(13) r.w. Section 144B of the Income Tax Act, 1961 (the Act in short) all dated 29.04.2022 pertaining to the Assessment Years 2017-18 and 2018-19 respectively.

2. The Assessee raised additional ground No.1 in all the appeals contending that the Final Assessment order all dated 30.04.2022 passed by the A.O. is time barred by limitation and is bad in law, as it has been passed beyond the time frame prescribed under section 153(1) read with section 153(4) of the Income Tax Act, 1961 ('Act' for short).

3. We have heard both parties and have perused material available on the record. A perusal of substantive ground of appeal and the application for admission of additional ground clearly indicate that this is legal ground assailing the validity of the assessment order and the order of the Ld. TPO. The Hon'ble Supreme Court of India in the case of National Thermal Power Company, 229 ITR 383 has held that the Tribunal has jurisdiction to examine a question of law which arises from the facts on record and have a bearing on the tax liability of the asses