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TMI Blog2021 (1) TMI 353X X X X Extracts X X X X X X X X Extracts X X X X ..... appeal filed by the Assessee is directed against the order of the Ld. CIT(A)-13, Ahmedabad dated 28.08.2019 pertaining to A.Y. 2011-12 and following grounds have been taken: 1. The learned assessing officer has erred in law by not providing a reasonable opportunity to the assesse. 2. The Ld. CIT(A) has failed to observe that out of total addition sustained by him of Rs. 28,20,275/- an amount ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 5. The Ld. A.O. has erred in initiating penalty u/s. 271(1)(c). 6. The Ld. assessing officer has to interpret the law liberally in view of fact and materiality based on various judgments. 2. Brief facts of the case are that the assessee is having income from salary, business and interest. And is NRI and he had not filed his return of income for the Assessment Year 2011-12. As per information a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the Ld. A.O. 5. At the outset, Ld. A.R. requested this matter may be set aside to the file of the lower authority and submitted that he has not received any noticed from the office of Ld. CIT(A). 6. On the other hand, Ld. D.R. relied on the order of the Assessing Officer. 7. We have heard both the parties and perused material available on record. Undisputedly, assessee did not appear before b ..... X X X X Extracts X X X X X X X X Extracts X X X X
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