2021 (4) TMI 817

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..... is filed by the assessee against order dated 25/09/2018 passed by CIT(A)-20, New Delhi for assessment year 2010-11. 2. The grounds of appeal are as under:- "1. (a) That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in not quashing the impugned reassessment order passed by Ld. AO u/s 147/143(3), more so when the same is passed without assumin .....

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..... ion has been made and that too by recording incorrect facts and findings and without providing the entire adverse material used against the assessee and without observing the principles of natural justice. 3. That in any case and in any view of the matter, action of Ld. CIT(A) in confirming the action of Ld. AO in making addition of Rs. 1,75,600/-, is bad in law and against the facts and circum .....

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..... . 5. The Ld. AR submitted that at the initial stages, the assessee has claimed loss of Rs. 44,638/- in the return of income for which the Assessing Officer has given an incorrect finding that the assessee never claimed loss. The assessee further submitted that the assessee was not aware at any time whether any Client Code Modification has been done by the broker. The Ld. AR submitted that any act .....

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..... the assessee has claimed loss of Rs. 44,638/- and at no point of time was aware about the Client Code Modification. All the details which were given by the assessee was before the Assessing Officer and at no point of time, the assessee was responsible for the Client Code Modification. The evidences and the circumstances clearly set out that assessee has never indulged into Client Code Modification .....

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..... the Act has clarified that no client code modification occurred during the Financial Year 2009-10 in the account of the assessee. These facts were not disputed by the Assessing Officer. The Ld. AR relied upon the decision of the Hon'ble Bombay High Court in case of M/s Coronation Agro Industries Ltd. Vs. DCIT WP No. 2627/2016 order dated 23/11/2016 which is apt in the present case. Thus, the CIT( .....

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