206 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH -.-

ITA-173-2013 (O&M)

Reserved on :- 16.01.2025 Date of Pronouncement: 11.02.2025 M.C.Anand ....Appellant VERSUS Commissioner of Income Tax, Jalandhar (Punjab) ....Respondent CORAM : HON'BLE MR. JUSTICE ARUN PALLI HON’BLE MRS. JUSTICE SUDEEPTI SHARMA Present: Mr. Divya Suri, Advocate, with Mr. Yogesh Kumar Mittal, Advocate, for the appellant.

Mr. Ranvijay Singh, Senior Standing counsel for the respondent.

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SUDEEPTI SHARMA, J.

1. The present appeal is preferred under Section 260-A of the Income Tax Act, 1961 (for short, ‘the Act’) for the assessment year 1982-1983 against order of Income Tax Appellate Tribunal, Amritsar Bench, Amritsar, in ITA No.

01/Asr/2011, dated 10.10.2012.

2. The present appeal was admitted for determination of the following substantial questions of law:-

i) Whether on the facts and in the circumstances of the case, the Tribunal order is sustainable on the true & correct interpretation of the Provisions of Section 154, 220(2) in setting aside the proceedings, read with the CBDT Circular No.334 of 1982 hence outside the scope of 'mistake apparent from the record'?

ii) Whether on the facts and in the circumstanc