JUDGMENT

The applicant has impugned a judgment rendered by the Appellate Tribunal Inland Revenue("Tribunal")dated 22.09.2020, pursuant to which the applicant's appeal against Order-in-Appeal No. 248 of 2020 dated 03.02.2020, was dismissed. The questions framed for our consideration were recorded in order dated 22.10.2020, asfollows:i. Whether on facts and in the circumstances of the case, the Appellate Tribunal Inland Revenue has erred in law in upholding that the Commissioner had the jurisdiction to pass the amended assessment order as the Commissioner retains concurrent powers of amendment of assessment under S. 122(5A) and of passing an amended assessment order under S. 122(6), despite delegation of both powers by him to the Additional Commissioner? ii. Whether on facts and in the circumstances of the case, the Appellate Tribunal Inland Revenue erred in law in failing to remand the question of jurisdiction to the Commissioner (Appeals-I)? iii. Whether on facts and in the circumstan...