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TMI Blog2022 (5) TMI 882X X X X Extracts X X X X X X X X Extracts X X X X ..... Finance Private Limited and it was duly explained by the assessee in their written submissions. In our considered opinion, whenever a quasi-judicial authority is deciding the issue, the authority should provide an opportunity to the assessee as well the Ld. Assessing Officer should also be given an opportunity and call for a remand report or call for the comments of the Ld. AO. Considering the discrepancy shown by the Ld. CIT(A), we are of the opinion that the order passed by the Ld. CIT(A) in not in accordance with the principles of natural justice by not granting an opportunity to the Assessing Officer for explaining whether there was any typographical error in the balance sheet of M/s. Anisha Estate and Finance Private Limited. In th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 5. Besides the merits in the facts and law, it is also submitted that there is an RAP audit objection in this case. For these and other grounds that may be urged at the time of appeal hearing, it is prayed that these disallowances of Rs. 49,50,000/- U/s. 68A of the IT Act made by the AO be restored. The appellant craves leave to add or delete or amend or substantiate any grounds of appeal before and/or at the time of hearing of appeal. 3. The fundamental ground raised by the Revenue is Ground No. 3 and Ground No. 4 of the above grounds of appeal. In this regard, the Learned Sr. DR drawn our attention to paras 8 and 8(a) of the Ld. CIT(A)'s order wherein the Ld. CIT had mentioned that there was some typographical error in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lance sheet of M/s. Anisha Estate and Finance Private Limited and it was duly explained by the assessee in their written submissions. In our considered opinion, whenever a quasi-judicial authority is deciding the issue, the authority should provide an opportunity to the assessee as well the Ld. Assessing Officer should also be given an opportunity and call for a remand report or call for the comments of the Ld. AO. Considering the discrepancy shown by the Ld. CIT(A), we are of the opinion that the order passed by the Ld. CIT(A) in not in accordance with the principles of natural justice by not granting an opportunity to the Assessing Officer for explaining whether there was any typographical error in the balance sheet of M/s. Anisha Estate ..... X X X X Extracts X X X X X X X X Extracts X X X X
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