9911796707
TMI Blog2022 (11) TMI 1206X X X X Extracts X X X X X X X X Extracts X X X X ..... "Act") dated 04.12.2019. 2. At the outset, we note that appeal of assessee is time barred by 99 days and a condonation petition has been placed on record. The impugned order of Ld. CIT(A) is dated 01.12.2021 and the assessee had received the order on the same day itself. The present appeal ought to have been filed by 29.01.2022. It is noted that the period of delay falls during the time of Pandemic of Covid-19 which has been excluded by the Hon'ble Supreme Court in the case of Suo moto Writ Petition (C) No. 3 of 2020 dated 10.01.2022 by which the period from 15.03.2020 to 28.02.2022 has been directed to be excluded for the purpose of limitation. Vide this order a further period of 90 days has been granted for providing the limitation from ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dividend income of Rs.19,23,488 once under the head "Income from Profit and Gains of Business or Profession" and also under Section 115BBDA of the Act thereby leading to double taxation of same income; Short grant of TDS credit 6. erred in granting TDS credit of Rs. 8,94,70,175 as against TDS credit of Rs.14,74,78,853 as claimed in Revised Return of Income, thereby granting short credit of TDS of Rs. 5,80,08,678; Levy of interest under Section 234B of the Act 7. erred in levying interest under Section 234B of the Act of Rs. 1,76,36,982; Levy of interest under Section 234C of the Act 8. erred in levying interest under Section 234C of the Act of Rs. 26,17,929; The Appellant craves leave to add, alter, vary, omit, substitute ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e perusal of the assessment order passed u/s. 143(3) of the Act, we note that Ld. AO has proceeded to compute the assessed income by making an addition to the returned income of the assessee and not the income processed u/s. 143(1) of the Act. However, it is noted that in the said order u/s. 143(3) of the Act, there is no addition made in respect of dividend income received from investment in units of mutual funds u/s. 115BBDA of the Act. We note that since the assessment order u/s. 143(3) of the Act has already been passed in the present case before us, the intimation u/s. 143(1) of the Act against which the assessee is in appeal before us got merged with the aforesaid assessment order. Once the present intimation u/s. 143(1) of the Act ha ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
