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2021 (1) TMI 459

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.... the assessee against the order dated 01/04/2015 passed by CIT(A)-18, New Delhi for Assessment Year 2012-13. 2. The grounds of appeal are as under:- "1. That Ld. CIT(A) without appreciating the correct facts of the case and without giving proper opportunity of being heard is not justified in law and facts and circumstances of the case in confirming the disallowance of Rs. 3,62,37,000/- on accou....

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....eciating the correct facts of the case and without giving proper opportunity of being heard is not justified in law and facts and circumstances of the case in confirming the disallowance of Rs. 2,27,930/- on account of 50% out of Deepawali expenses on estimation basis. 5. That Ld. CIT(A) without appreciating the correct facts of the case and without giving proper opportunity of being heard is no....

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....s on estimation basis. 8. That Ld. CIT(A) without appreciating the correct facts of the case and without giving proper opportunity of being heard is not justified in law and facts and circumstances of the case in confirming the disallowance of Rs. 19,59,215/- out of interest paid on borrowed funds for the advance paid to staff. 9. Appellant has every right to make, add, delete, modify or alter....

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....e material available on record. It is pertinent to note that the CIT(A) has not given any categorical finding on merit of the case and dismissed the appeal on the ground of non-prosecution of appeal. Before the CIT(A) none appeared on behalf of the assessee. From the perusal of the order of the CIT(A), it can be seen that the CIT(A) has not given any categorical finding on merit of the case. There....