2020 (7) TMI 151

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....ellant by confirm the additions made by the Ld AO by treating Exempt Interest and Rental income under section 10(24) of I Tax Act 1961 for Rs. 1043749.00 as Taxable income of the assessee without providing the sufficient opportunity of being heard, without providing the copy of recorded reason for issuing the notice under section 148, only on the basis that the assessee has not file any evidence in respect to Exempt Income are not according to the law and facts of the case. The appellant prays your honours indulgence to add, amend or alter any of the grounds of appeal on or before the date of hearing. 2. The Hon'ble Commissioner of Income tax appeals has not justified to appellant by passing the order under section 144/147 of t....

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....44 of the Act by treating the return of income filed by the assessee as not valid and consequently, the A.O. has assessed total income at Rs. 10,43,749/- which was shown by the assessee in its return of income. The A.O. has denied the claim of exemption U/s 10(24) of the Act for want of any evidence in support of the said claim. 3. The assessee challenged the action of the A.O. before the ld. CIT(A) but again there is no representative on behalf of the assessee before the ld. CIT(A) and consequently, the appeal of the assessee was dismissed ex parte while passing the impugned order. 4. Before the Tribunal, the ld. AR of the assessee has submitted that despite specific requests by the assessee, the A.O. has not supplied the reasons rec....

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....t there was no return of income U/s 139 of the Act filed by the assessee and even there is no valid return in response to the notice U/s 148 of the Act. Therefore, the A.O. is no obliged to furnish the reasons recorded for reopening of the assessment. The ld DR has further contended that the assessee has not filed any documentary evidence in support of the claim of exemption U/s 10(24) of the Act. All these documents filed by the assessee are additional evidences first time produced before the Tribunal, therefore, the claim of the assessee cannot be accepted when the assessee itself has failed to furnish the return of income as well as documentary evidences in support of the claim. She has relied upon the orders of the authorities below. ....