2021 (1) TMI 1062

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....radeshi, DR ORDER PER PAVAN KUMAR GADALE - JM: This appeal filed by the assessee is directed against the order of the Commissioner of Income Tax (Appeals)-20, Mumbai passed u/s 144 and 250 of the Act. The assessee has raised the following grounds of appeal "1. On the facts and under the circumstances of the case and in law, the Ld. CIT(A)-20, Mumbai erred in dismissing the appell....

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....der the circumstances of the case and in law, the Ld. CIT(A) erred in not appreciating that there is a totaling error of Rs. 11, 43, 743 made by the Ld. AO which has to be deleted. 5. On the facts and under the circumstances of the case and in law, the Ld. CIT(A) erred in not deleting interest u/s 234B and 234D charged by the Ld. A.O 2. Brief facts of the case are that, the assessee co....

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....limine as there was a delay of more than seven year in filing the appeal. Aggrieved by the order of the CIT(A), the assessee has filed an appeal with the Hon'ble Tribunal. 3. At the time of hearing Ld. AR of the of the assessee submitted that the CIT(A) has passed the order without considering the material facts, affidavit and details filed in the course of appellate proceedings. The Ld. AR ....

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....ct and dismissed the appeal in limine. The Ld. AR emphasized and referred to the additional evidences filed under Rule46A of IT Rules1962 before the CIT(A) on 01.03.2016 at page 2 of paper book and the affidavit filed on 16.11.2018 at page 23 of paper book explaining the receipt of the copy of the assessment order u/s 144 of the Act. We found strength in submissions of the Ld. AR and the Ld CIT(A)....