9911796707
TMI Blog2025 (5) TMI 208X X X X Extracts X X X X X X X X Extracts X X X X ..... referred to as "the Act"), generated vide DIN: ITBAINF AC/S/250/2023- 24/1059629706(1), dismissing the grounds of appeal and sustaining the total income at Rs. 28,81,766/- in place of returned income as returned by the assessee is bad in law on account of several grounds and assessee/appellant denies its liability to be assessed for any income other than the income already returned by the assessee and the consequential demand of Rs. 13.91,270/-. 2. That under the facts and circumstances of the case the Ld. CIT(A) has erred in law as much as in fact while passing the impugned order as the Ld. CIT(A), has confirmed the addition made by the Ld. AO without appreciating the submissions made by the assessee during appeal proceedings. 3. That ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e impugned order, as the Ld. CIT(A) has upheld the addition made by the Ld. AO without providing any corroborative evidence and without even giving the assessee an opportunity of explanation and being heard on the basis of the addition made by the Ld. AO. 2. Subsequently assessee has filed additional grounds of appeal as under :- "1. On the facts of the case and in law, the notice u/s 148 issued in this case is bad-in-law, without jurisdiction and barred by limitation and, therefore, the said notice and assessment order passed is liable to be quashed. 2. On the facts of the case and in law, the reassessment proceedings initiated are contrary to provisions of section 147 to section 151 of the Act and therefore, the assessment order pass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s books of account which shows that assessee was doing business regularly and profit from the same was not disclosed. Accordingly, he estimated 8% of the total business receipts and proceeded to treat the same as additional income of the assessee. He submitted that the reassessment proceedings were initiated on the basis of cash deposits. However, Assessing Officer proceeded to rake-up other issues and not made addition relating to the issue on which the show-cause notice was issued. He submitted that the decision of Hon'ble Bombay High Court in the case of CIT vs. Jet Airways (I) Ltd. (2010) 331 ITR 236 (Bom.) squarely applicable in this case. 5. On the other hand, ld. DR of the Revenue relied on the orders of the lower authorities. 6. C ..... X X X X Extracts X X X X X X X X Extracts X X X X
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