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TMI Blog2022 (9) TMI 71X X X X Extracts X X X X X X X X Extracts X X X X ..... producing all books of accounts and vouchers and he having test checked the same. Nothing adverse has been found by the AO in the books of the assessee also. The disallowance surely is purely adhoc. We see no reason to uphold the disallowance and we direct the deletion of the same. Set off of unabsorbed loss of preceding year - We direct the AO to grant benefit of set off of brought-forward losses if any as available as per law. - ITA No. 186/RJT/2018 - - - Dated:- 3-8-2022 - SMT.ANNAPURNA GUPTA , ACCOUNTANT MEMBER AND SMT.SUCHITRA KAMBLE , JUDICIAL MEMBER Assessee by : Shri Kalpesh Doshi , Ld. AR Revenue by : Shri B. D. Gupta , Ld. Sr. DR ORDER Per Annapurna Gupta , Accountant Member Present appeal has been f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... This being erroneous needs deletion. 5. Without prejudice, the assessment made is bad in law and deserves annulment. 6. Without prejudice, no adequate, sufficient and reasonable opportunity has been provided at the time of assessment stage. The assessment needs annulment. 7. Without prejudice, no adequate, sufficient and reasonable opportunity has been provided at the time of appellate stage. The assessment needs annulment. 8. Without prejudice, no legal and statutory notice has been served on the assessee the assessment being bad in law deserves annulment. 9. The appellant craves leave to add/alter/amend and/or substitute any or all ground of appeal before the actual hearing takes place. 4. With regard to the i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he said year, the entire losses were wiped off and income assessed at Rs. 61,50,420. He pointed out from the assessment order that the AO gave no benefit of carry forward of loss noting none was available to the assessee. Ld. Counsel for the assessee contended that the assessee had carried the matter, relating to the additions made in the preceding year, in appeal before the ld. CIT(A) which was pending. He stated therefore that in the circumstances, the assessee appeal is allowed, to the extent that losses are assessed in the said year, the assessee should be allowed carry forward and the set off the same in the impugned year. He prayed therefore for direction to the AO to the effect that benefit of brought forward assessed losses be given ..... X X X X Extracts X X X X X X X X Extracts X X X X
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