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Income Tax Appellate Tribunal, PUNE BENCH, ‘C’ PUNE
Before: SHRI R.S. SYAL & SHRI PARTHA SARATHI CHAUDHURY
आदेश / ORDER
PER R.S. SYAL, VP : The assessee has moved an application requesting for withdrawal of Corrigendum issued by the Tribunal on 01.11.2022 in . 2. We have heard the parties and gone through the relevant material on record. The factual matrix of the case is that the Tribunal passed an order dated 31-10-2022 in the captioned appeal. Last page of the order records “Copy of the order is forwarded to”, inter alia, “3. The CIT(A)-13, Pune and 4. PCIT-5, Pune”. Thereafter, it was realized at the time of uploading the order that the Assessing Officer
M/s. Faurecia Automotive Seating India Private Limited passed the final assessment order u/s.143(3) read with section 144C(13) of the Income-tax Act, 1961 on the basis of the directions dated 19-09-2017 issued by the Dispute Resolution Panel-1, Bengaluru. Considering this fact, the corrigendum was issued marking the copy to “4. The DRP-1, Bengaluru and 5. The Pr.CIT-3, Bengaluru” instead of “4. The CIT(A)-13, Pune and 5. The PCIT-5, Pune”. The assessee has moved the instant application urging that the original order was marked correctly to The CIT(A)-13, Pune and The PCIT-5, Pune. In our considered opinion, when the appeal was filed against the order passed by the AO pursuant to the direction of the DRP, Bengaluru and not against that of the CIT(A)-13, Pune, a copy of the order ought to have been marked to The DRP-1, Bengaluru and The Pr.CIT-3, Bengaluru as the CIT(A)-13, Pune had no relation with the appeal. We are, therefore, not inclined to entertain the application of the assessee.
In the result, the application is not allowed. Order pronounced in the Open Court on 08th August, 2023.
Sd/- Sd/- (PARTHA SARATHI CHAUDHURY) (R.S.SYAL) JUDICIAL MEMBER VICE PRESIDENT पुणे Pune; िदनांक Dated : 08th August, 2023 सतीश
M/s. Faurecia Automotive Seating India Private Limited