2020 (9) TMI 721

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....ad both in the eye of law and on facts. 2. (i) On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in passing the order without giving assessee an opportunity of being heard in violation of principle of natural justice. (ii) That the non-appearance before the Ld. CIT(A) was due to reasons beyond the control of the assessee. 3. On the facts and circumstances of the case, the learned CIT(A) has erred, both on facts and in law in passing the order Ex Parte without giving any findings on the merits of the case. 4. On the facts and circumstances of the case, the learned CIT(A) has erred, both on facts and in law, in confirming the order despite the fact that the initiation of the proceedings ....

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....s and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirming the addition of Rs. 67,500/- on account of commission made by A.O., without there being any basis for the same. 10. On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirming the addition despite the assessee bringing on record all material and evidences to prove the identity and creditworthiness of the lenders and genuineness of the transactions. 11. On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirming the above said addition which was made on the basis of material collected at the back of the assessee without giving it an opp....

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....6. On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirming the order of the A.O. despite the fact that the reassessment proceedings initiated by the learned A.O. are bad in the eye of law as there is no independent application of mind applied by the A.O while forming belief for the purpose of recording of reasons." 4. Firstly we are taking up the facts of ITA No. 9291/Del/2019. The assessee company is a NBFC company. In response, notice issued u/s 148 of the Income Tax Act, the assessee filed return of income on 15/9/2018 declaring income of Rs. 48,049/-. During the course of assessment proceedings, the assessee company was asked to explain the amount of accommodation entry of Rs. 32,....