9911796707
TMI Blog2024 (2) TMI 42X X X X Extracts X X X X X X X X Extracts X X X X ..... the learned Commissioner of Income Tax (Appeals) [CIT (A)] is bad both in the eye of law and on facts 2. On the facts and circumstances of the case, learned CIT (A) has erred, both on facts and in law, in rejecting the contention of assessee that the assessment order passed is bad in the eyes of law as the same was passed in violation of circular no. 19/2019 issued by CBDT which mandates that no order shall be passed without there being Valid Document Identification Number (DIN). 3. On the facts and circumstances of the case, the learned CIT (A) has erred, both on facts and in law, in rejecting the contention of the assessee that the assessment order passed under section 153A r.w.s. 143(3) is bad and liable to be quashed as the same ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d adequate opportunity to the appellant to rebut the same. 8. On the facts and circumstances of the case, the learned CIT (A) has erred, both on facts and in law, in rejecting the contention of the assessee that the proceedings initiated under section 153A against the appellant and the assessment framed under section 153A r.w.s. 143(3) are in violation of the statutory conditions of the Act and the procedure prescribed under the law and as such the same is bad in the eye of law and liable to be quashed. 9. On the facts and circumstances of the case, the learned CIT (A) has erred, both on facts and in law, in rejecting the contention of the assessee that notice issued u/s 142(1) of the Act is bad in law as no assessment proceedings wer ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ame to be passed on 27/12/2019 by making additions not based on any incriminating material found during the course of search. Therefore, submitted that addition made by the AO which has been confirmed by the Ld. CIT(A) requires to be deleted in view of the settled position of law and the ratio laid down by the Hon'ble Supreme Court in the case of PCIT vs. Abhisar Buildwell Pvt. Ltd. [2023] (4) TMI 1056 (SC). 3. Per contra, the Ld. DR though relied on the orders of the lower authorities did not dispute the fact that the addition were made by the A.O. not based on the incriminating material unearth during the course of search. 4. We have heard the parties and perused the materials available on record and considering the submissions made by ..... X X X X Extracts X X X X X X X X Extracts X X X X
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