Bholaram Malviya , Mumbai vs Income Tax Officer W-16(1)|(1), Mumbai on 21 April, 2023
31. Since no decision contrary to the above case laws has been
brought to our notice, respectfully following the above decisions of the
Hon'ble Supreme Court, High Courts and the Tribunal in M/s. Sahara
City Homes, Bareilly Vs. ITO dated 31.01.2022 (ITA. No.
24/Lkw/2019 to ITA. No. 39/Lkw/2019), we are of the view that the
Ld. CIT(A) had no power to issue directions to the Assessing Officer
to reopen the assessment for earlier/subsequent Assessment Years
which was not in appeal before him.