2025 (2) TMI 1130

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... appeal, assessee has raised following grounds of appeal : "1. That the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi erred in passing an order dated 3rd of June, 2024 under section 250 of the Income Tax Act, 1961 partly dismissing the appeal of the Appellant without allowing reasonable opportunity of being heard violating the principle of natural justice. 2. That the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi erred in partly dismissing the appeal of the assessee although the assessment order dated 20th December, 2016 passed by the ITO, Ward 9(3), Kolkata under section u/s 147/143(3) of the Income Tax Act, 1961 was without jurisdiction, illegal and void ab initio. 3. .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... saction of the assessee appeared to be accommodation entry on irrelevant considerations and arbitrary grounds. 8. That the National Faceless Appeal Centre, Delhi erred in confirming the addition of Rs. 8,00,000/-, as unexplained income under section 69 of the Income Tax Act, 1961 in complete disregard of the binding judgments of Hon'ble Apex Court, Hon'ble Jurisdictional High Court and the Hon'ble Jurisdictional ITAT, which directly lays down a ratio on the merit of the addition of unexplained income under section 69 of the Income Tax Act, 1961. 9. That the appellant craves leave to add, alter or delete all or any of the grounds of appeal. 3. The assessee has raised as many as Nine grounds of which Grounds of appeal No.1 to .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... e disallowance u/s. 14 of the Act since no exempt income was earned by the assessee and sustained the addition made u/s. 69 of the Act. 7. Now the assessee is in appeal before the Tribunal by raising the above-mentioned grounds of appeal. 8. Ld. Counsel for the assessee vehemently argued referring to the details furnished in the paper book containing 37 pages challenging the validity of reassessment proceedings, no proper approval u/s. 151 of the act and also contending that addition on merits is uncalled for as it is a simple transaction of sale consideration received from sale of Equity Shares held by the assessee. 9. On the other hand, ld. Departmental Representative relied on the order of the lower authorities. 10. I have heard the .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X