Sec. 143(3) & 154 of Income Tax Act, 1961 – Appeal – The assessee–appellant filed its return declaring a total income of “Nil”. The AO under section 143(3) of the Act, assessed the total income of the appellant at Rs. 70,80,040/– and imposed tax liability of Rs. 27,62,035/–. The appellant filed an application for rectification under section 154 in respect of the aforesaid order. The AO rejected the same observing that the appellant having failed to file the revised return within the prescribed period of limitation or having failed to make relevant claims during the course of assessment proceedings. CIT(A) allowed the appellant's appeal made under section 143(3) of the said Act. However, ITAT quashed the order of CIT(A) in the appeal of revenue. Thus, the assessee–appellant filed the appeal before High Court raising two substantial questions of law in respect of jurisdiction of CIT(A) of entertaining additional grounds. High Court disposed of appeal holding that:- the CIT (A) has the jurisdiction to entertain the two additional grounds/claims raised by the appellant before it.  However, we have also held that in the exercise of such jurisdiction, the CIT (Appeals) has not properly dealt with the said additional grounds/claims on their merits. Hence, the necessity of remand to CIT (A) to deal with the said two additional grounds/claims on merits – SIVA EQUIPMENT P. LTD. Vs. ASSTT. CIT [2020] 423 ITR 20 (BOM)