9911796707
TMI Blog2024 (2) TMI 42X X X X Extracts X X X X X X X X Extracts X X X X ..... . - SHRI N. K. BILLAIYA, ACCOUNTANT MEMBER AND SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER For the Appellant : Sh. Ved Jain, Adv. and Ms. Supriya Mehta, CA For the Respondent : Sh. Prakash Nath Barnwal, CIT-DR ORDER PER YOGESH KUMAR U.S., JM: This appeal filed by the Assessee against the order of Learned Commissioner of Income Tax (Appeals)-30, New Delhi, [ Ld. CIT(A) , for short], dated 19/09/2022 for Assessment Year 2015-16. The following grounds of appeal taken by the assessee: 1. On the facts and circumstances of the case, the order passed by 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 C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... against the appellant and the assessment framed under section 153A r.w.s 143(3) are in violation of mandatory provisions of Section 153D of the Act and as such the same is bad in eyes of law. The purported approval u/s 153D of the Act is illegal, bad in law and also without any application of mind. 7. 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 assessment order was passed relying upon the material and evidences without providing the copies of same to the appellant and without providing proper and 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... irming interest charged u/s 234A, 234B, and 234C of the Act. 14. On the facts and circumstances of the case, the learned CIT (A) has erred in facts and in law in confirming the action of Assessing Officer in determining tax liability as per section 115BBE of the Act. 15. That the appellant craves leave to add, amend or alter any of the grounds of appeal. 2. The Ld. Counsel for the assessee submitted, the search was conducted on Bajaj Group and its associates including the assessee on 20/04/2017, there was no incriminating material/document was found as is evident from the Punchnama and the assessment order came to be passed on 27/12/2019 by making additions not based on any incriminating material found during the course of ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
