9911796707
TMI Blog2021 (10) TMI 618X X X X Extracts X X X X X X X X Extracts X X X X ..... der passed by the Hon'ble CIT (A) is wrong, having no base and against the circumstance of the case. 3. That on facts and circumstances of the case and in Law, the assessing officer had erred in assessing the income tax of the appellant at Rs. 10,21,510, please be deleted. 4. That the Ld. Assessing Officer had erred on facts and circumstances of the case and in law in making an addition on account of cash Deposit by the Assessee of Rs. 14,00,000.00, being wholly based on conjecture and surmises and being untrue, the same must be deleted. 5. The addition made by the A.O. is devoid of any merits and is away from the factual matrix. The Submission is not made by the Assessee. The Cash received against earlier sold agriculture land by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the findings of the Ld. CIT(A) and submitted that the Ld. CIT(A) has written thesis but ignored the details to adjudicate the issue on merit. He submitted that the issue is with regard to the deposit of cash in the account of the assessee amounting to Rs. 14 lakhs. He submitted that the explanation of the assessee before the lower authorities was that the assessee's husband sold agricultural land on 30.01.2009 of Rs. 19 Lakhs. Since, her husband did not maintain any bank account; the sale consideration received in cash was deposited in assessee's bank account. The assessee was neither owner of the sale consideration nor such amount was from any undisclosed sources. He contended that the assessee being an illiterate lady was not conversant ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hich is mandatory under the law and as per the law laid down by the jurisdictional High Court being the Hon'ble High Court of Judicature at Allahabad. The appellant has waived his rights for getting notice u/s 143(2) of I.T. Act, 1961 and has not pleaded that the appeal of the appellant be decided qua merits of the case ignoring the issue of non-compliance of due procedure by the Ld. A.O. to frame the impugned assessment. However, this issue of non-assumption of due jurisdiction by the Ld. A.O. can be considered & decided only in an admitted appeal & the issue of admission of an appeal needs to be decided by this office before taking up & considering the issue of nonissuance of notice u/s 143(2) of I.T. Act, 1961 and the correctness or othe ..... X X X X Extracts X X X X X X X X Extracts X X X X
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