2023 (3) TMI 921

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..... .M. This assessee's appeal for assessment year 2014-15, arises against the National Faceless Appeal Centre [in short "NFAC"], Delhi's Din & Order No.ITBA/NFAC/S/250/2022- 23/1048081678(1), dated 19.12.2022, involving proceedings under Section 154 of the Income Tax Act, 1961 (in short "the Act"). Heard both the parties. Case file perused. 2. The assessee pleads the following substantive grounds .....

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..... ted to the assessee in this respect. 3) The Appellant prays to be allowed to add, amend, modify, rectify, delete, raise any ground of appeal before or at the time of hearing." 3. The assessee's above extracted pleadings make it clear that its sole substantive grievance challenges correctness of both the learned lower authorities action invoking sec.154 rectification jurisdiction for the purpose .....

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..... the impugned sum involving S/Shri Dilip N Bharne proprietor of M/s. Trimurti Enterprises and Clincy Constructions Pvt. Ltd. is in the nature of service tax component which already stands assessed as the Assessing Officer had framed the scrutiny assessment dated 26.10.2016 after carrying-out his detailed investigation qua the alleged excess turnover declared, ITS data and 26AS, as the case may be. .....

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