TaxTMI 
TaxTMI 
2021 (4) TMI 715
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.... facts for the sake of convenience are taken from ITA No. 146/Gau/2020 A.Y 2015-16 in the case of Smt. Kene Welly. ITA No. 146/Gau/2020 A.Y 2015-16. 2. The assessee in this appeal has taken the following grounds of appeal:- 1. For that the order passed by the learned Commissioner of Income Tax (Appeals) [CIT(A)] is bad in law, facts and procedure. 2. For that the ld. CIT(A) ought to have held that in absence of any notice under section 143(2) of the Act having been issued by the ld. AO, the impugned order of assessment is without jurisdiction and unsustainable. 3. For that the ld. CIT(A) has erred in not holding that the order of assessment passed by the ld. AO in absence of an order passed under section 127 of the Act by a competen....
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....les of natural justice. The enhancement so made being bad in law is liable to be deleted in its entirety. 8. For that the impugned order passed by the ld. CIT(A) is bad in law, vitiated and is liable to be quashed as the ld. CIT(A) proceeded in the instant case in a biased manner, in excess of his jurisdiction and with a pre-conceived conclusion and the appellant was blatantly denied justice. 9. For that the ld. CIT(A) was not justified in arbitrarily enhancing income of the appellant by withdrawing exemption under section 10(26) of the Act in respect of Rs. 42,51,542/- (Rs. 50,51,542/- minus Rs. 8,00,000) without properly appreciating the entire facts of the case in its proper perspective and in gross violation of principles of natural....
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.... to show that the case laws relied upon by him are not applicable and/or distinguishable on facts, impugned order is bad in law and unsustainable. 13. For that the appellant cannot be assessed at the higher amount and the statutorily allowable exemption and/or deduction cannot be denied to her without any material to show that income of even a single rupee was earned outside the specified tribal area merely on surmises and conjecture and for the reason that her husband is a government employee. 14. For that the various adverse remarks, comments and directions stated by the ld. CIT(A) in the impugned order being in excess of the jurisdiction the same are bad in law and the same are liable to be expunged. 15. For that your appellant cra....
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....such circumstances, the ITO, Ward-I Tezpur should have issued notice u/s. 143(2) of the Act, which is sine qua non for initiation of the assessment proceedings u/s. 143(3) of the Act. Though, the above plea relating to the transfer of the case by the Ld. JCIT from ITO, Ward Itanagar to ITO, Ward-1, Tezpur has not been disputed by the Ld. DR, but he has contended that the case was duly transferred by the Ld. JCIT by exercising his jurisdiction for allocation of case to different ITOs (Income-tax Officers). That the assessee was required to object to the jurisdiction of the AO within one month from the date of initiation of assessment proceedings as per provisions of section 124(3) of the Act. However, the assessee at that time did not raise ....