In the result, the appeal of the assessee in ITA No
147 read with sections 144 and 144B\nof the Income Tax Act, 1961 (“the Act”), dated 29.03.2022. The Ld. CIT(A)\ndismissed the appeal of the assessee by confirming the order passed by the\nLd. AO.\n4.\nAggrieved with the order of Ld. CIT(A), the assessee is in further appeal\nbefore this Tribunal. At the outset we find that