TMI Blog2020 (3) TMI 944X X X X Extracts X X X X X X X X Extracts X X X X ..... e order, the ld. CIT(A) has not adjudicated the issues on merits based on the facts and circumstances. Accordingly, we set aside the order of the ld. CIT(A) and direct the ld. CIT(A) to adjudicate the issues on merits in accordance with law and to meet the ends of justice, the assessee may be given an opportunity of being heard to present its case. The assessee shall furnish detailed explanation/evidences, as the case may be, to substantiate its claim for adjudication. Further, the assessee is directed to appear before the ld. CIT(A) and cooperate to conclude the appellate proceedings, as has been committed before the Tribunal by its letter dated 25.02.2020. Thus, the ground raised by the assessee is allowed for statistical purposes. - I. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ly, the assessments were completed under section 143(3) r.w.s. 92CA of the Act by assessing the income of the assessee for the assessment year 2012-13 at ₹ 95,27,85,096/- against the returned income of ₹ 42,74,07,280/-, for the assessment year 2013-14 at ₹ 45,07,36,808/- against the returned income of ₹ 16,32,73,820/- and for the assessment year 2014-15 at ₹ 206,73,79,414/- against the returned income of ₹ 179,74,56,760/-. 2.1 Further, during the course of verification of Form 15CA/CB filed by the assessee for the financial year 2013-14, the Assessing Officer noticed that the assessee had not deducted TDS to the extent of ₹ 10,70,86,629/- on the payment made to the non-residents on various dates ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lable on record and gone through the orders of authorities below. Against various additions made in the assessment order passed under section 143(3) r.w.s. 92CA of the Act for the assessment years under consideration, the assessee preferred appeal before the ld. CIT(A). On perusal of the appellate order, we find that while concluding the appellate order, the ld. CIT(A) has not adjudicated the issues on merits based on the facts and circumstances. Accordingly, we set aside the order of the ld. CIT(A) and direct the ld. CIT(A) to adjudicate the issues on merits in accordance with law and to meet the ends of justice, the assessee may be given an opportunity of being heard to present its case. The assessee shall furnish detailed explanation/evi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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