2020 (12) TMI 1140

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....ts and circumstances of the case, the order passed by the learned Assessing Officer ('AO') and Commissioner Income Tax Appeals ('CIT(A)') is bad both in the eye of law and on facts. 2. On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirming the action of the AO by not providing reasonable opportunity of being heard and thereby violating the principles of natural justice. 3. On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirming the action of the AO and rejecting the contention of the assessee that the no notice under section 148/143(2)/142( 1) of the Income Tax Act, 1961, ('the Act') was served on the assesse du....

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.... addition of Rs. 42,30,500/- made by the AO on account of investment in agricultural land without any evidence on record. 8. On the facts and circumstances of the case, the learned CIT(A) has grossly erred both on facts and in law in confirming the above addition by indulging in surmises without bringing on any direct evidence against the assesses, only on the basis of presumption and assumption. 9. On the facts and circumstances of the case, the learned CIT(A) has grossly erred both on facts and in law in confirming the action of the AO by passing the order without discussing the merits of the case, which is in gross violation of section 250(6) of the Act. 10. On without prejudice basis the learned CIT(A) has err....

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....4.12.2018. 2. That in the said assessment order dated 04.12.2018 it has been mentioned that several notices like notices under section 133(6) of the Act dated 21.02.2018 and 15.03.2018 were issued and served on me, notice under section 148 of the Actwvas issued and served on me on 28.03.2018. It is also stated that notices under section 142(1) dated 01.08.2018 and 08.10.2018 were issued and served on me. 3. That I solemnly state and affirm that no notice under section 133(6)/148/142(1) or any hearing notice under the Act for the AY 2011-12 has been received by me before the receiving of the reassessment order dated 04.12.2018. 4. Thereafter, I was in receipt of the assessment order dated 04.12.2018 along with the ....