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1. These cross appeals filed by the assessee and Revenue are against the order of the ld. Commissioner of Income Tax (Appeals)-29, New Delhi ["ld. CIT(A)", for short] dated 27.06.2024 for the AY 2011-12.

2. The grounds of appeal raised by the assessee in ITA No.3550/Del/2024 are as under :-

1. "That on the facts and in the circumstances of the case, the order passed by the assessing officer was bad in law, violative of principles of natural justice and void-ab-initio.

2) That the appellant has timely filed the appeal before the Hon'ble ITAT on 05.08.2024 wherein 9 grounds have been raised by the appellant. Copy of the Form 36 so filed on 05-08-2024 is enclosed herewith.

3) Request for Revision of Ground No.1. only in Form 36:-

Original Ground No. 1 reads as under:-

"That on the facts and in the circumstances of the case, the order passed by the assessing officer was bad in law, violative of principles of natural justice and void-ab-initio."

It is prayed before the Hon'ble Bench that Ground No.1 may be allowed to be revised as under: -

, Revised Ground No. 1:-

"That on the facts and in the circumstances of the case, the order passed by the assessing officer was bad in law, violative of principles of natural justice, without jurisdiction as passed by non-jurisdictional AO that too without following the mandatory procedure in law of issuance of valid notice u/s 143(2) of the Act, barred by limitation and thus, void-ab-initio."

4) That the aforementioned revision to add "out of jurisdiction as passed by non-jurisdictional AO that too without following the mandatory procedure in law" relates to the facts already on record and has been inadvertently left by the appellant at the time of filing of appeal.

6) That it is most respectfully submitted that rest of the Grounds of Appeal namely Ground 2- 9 remains unchanged.

In view of the above, it is hereby most humbly prayed before your honors to kindly take the Revised Ground No.1 on record while adjudication of the said appeal matter keeping in view the principles of natural justice and oblige."

4. The Ld. AR submitted that vide the aforesaid application dated 10.02.2025, the assessee company has just elaborated the Ground no. 1 taken originally while filing the appeal that as to how the assessment order is void ab initio and bad in law. The said revision emanates from the objections raised before the Ld. AO as well as from the Grounds already raised earlier before the Ld. CIT(A) in context to wrongly assuming jurisdiction of framing the disputed assessment which were not properly considered by the Ld. AO and the CIT(A) while disposing the first appeal and moreover, the said revision goes to the root of the matter.