These two appeals by the assessee are directed against the final Assessment orders dated 18-09-2018 and 31-07-2019 passed by the Assessing Officer (AO) u/ss.144C(13)/143(3) read with section 263 of the Income-tax Act, 1961 (‘the Act’) in relation to the assessment years 2011- 12 and 2012-13 respectively.
Judges have heard the rival submissions and gone through the relevant material on record. The instant assessments emanated from the proceedings arising from the revisionary order passed by the ld. CIT u/s 263 of the Income-tax Act, 1961 (‘the Act’) for both the years. Such orders were also challenged by the assessee before the Tribunal along with the instant appeals. All the appeals were heard together.
Judges have passed separate orders in such appeals filed by the assessee in ITA No.1217/KOL/2017 and ITA No.1334/KOL/2018 quashing the revisionary orders passed u/s 263 of the Act. Since the very foundation for the extant proceedings, being the revision orders, are no more existing, the assessment orders and the consequential impugned orders are, therefore, liable to be set aside. In view of our above decision, there is no need to separately go into the merits of the grounds taken in these appeals.