आदेश/ORDER

Per Paresh M Joshi, J.M.:

This is an Appeal filed by the Assessee under section 253 of the income tax Act 1961,[ herein after referred to as the Act for the sake of brevity] before this tribunal as & by way of a second Appeal. The Assessee is aggrieved by the order bearing Number:-1046/2021-22 dated 29.07.2022[DR No. 39/12 D No. 427] passed by the Ld. CIT(A) u/s 250 of the Act, which is herein after referred to as the “Impugned order”. The Relevant Assessment year is 2006-07 and the corresponding previous year period is from 01.04.2005 to 31.03.2006.

2. Factual Matrix

2.1 That as and by way of an assessment order made u/s 143(3) of the Act the balance losses of AY 2005-06 were carried forwarded to Rs. 20,20,76,816/-. The total Income as per the ROI was at Rs. 1,57,87,570/-. The Ld. AO in the aforesaid assessment order has made following additions as below:-

The total income was assessed at Rs. 4,31,50,471/-. Less set off of b/F losses as per order u/s 143(3) dated 29.12.2007 of AY 2005-06 Rs. 24,52,27,287/-.That the aforesaid assessment