9911796707
TMI Blog2025 (5) TMI 1309X X X X Extracts X X X X X X X X Extracts X X X X ..... UNTANT MEMBER : This appeal at the instance of assessee is directed against the order u/s 250 of the Act dated 09.01.2025 for Assessment Year 2018-19 framed by Ld. CIT(A), Pune 13 and is arising out of assessment order passed by NFAC, Delhi (AO) u/s 143(3) r.w.s 144C(3) of the Income Tax Act, 1961 herein after referring as Act, dated 08.11.2021. 2. Assessee has raised following grounds of appea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ) executed by the Appellant with the CBDT on 21 December 2021 and the modified return of income fled by the Appellant on 31 March 2022. 3. On the facts and in the circumstances of the case and in law, the Hon'ble CIT(A) erred in not appreciating that no disallowance of INR 17,16,421 was warranted since the said amount was on account of notional interest recorded in the statement of profit a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n the circumstances of the case and in law, the Hon'ble CIT(A) erred in not appreciating that the Appellant ought to have been granted due credit of TDS, resulting in consequential refund along with interest. 8. On the facts and in the circumstances of the case and in law, the Hon'ble CIT(A) failed to appreciate that the learned AO has erred in initiating penalty proceedings under secti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssee. 5. We have heard rival contentions and perused the record placed before us. 6. Impugned order is ex-parte. Assessee did not attend to the first date of hearing fixed on 21.02.2024 and thereafter filed adjournment on dates fixed on 22.07.2024 and 10.12.2024 and on the final date of hearing given on 09.01.2025, in the absence of any representative, Ld. CIT(A) framed the impugned order on the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... re in the larger interest of justice and being fair to both the parties, we deem it appropriate to remit all the issues raised on merits of the case challenging the additions made by the AO back to the file of Ld. CIT(A) for necessary adjudication as contemplated in section 250(6) of the Act for which proper opportunity of hearing shall be granted to the assessee. Assessee is also directed to rema ..... X X X X Extracts X X X X X X X X Extracts X X X X
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