2021 (4) TMI 715
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....are taken together for adjudication. The 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 a....
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....alid show cause notice in terms of sub-section (2) of section 251 of the Act and in gross violation of principles 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 ....
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....sregard to the principles of natural justice and merely on the basis of imaginations and suppositions, ignoring the various materials on record and without allowing any opportunity 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 a....
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....r. Learned Counsel for the assessee has submitted that the Ld. JCIT did not have any power to transfer the case in which assessment proceedings had already commenced. Even if the case was re-allocated, in 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 ....
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