2021 (9) TMI 1036

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.... of Income Tax (Appeals)-8, New Delhi ['CIT(A)'] has erred in passing the order under section under section 250 of the Income Tax Act, 1961 ('Act'), confirming the adjustments made by the Deputy Commissioner of Income Tax, Circle 23(2), New Delhi ('AO') in the assessment order passed under section 143(3) of the Act. Each of the ground is referred to separately, which may kindly be considered independent of each other. 1. Ground No. 1 - The order passed by learned CIT(A) is bad in law 1.1 On the facts and circumstances of the case and in law, the learned CIT (A) has erred in not appreciating the submissions as well as the case laws relied upon by the Appellant, while summarily rejecting it by relying on the order passed by ....

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....nder section 271(l)(c) of the Act is premature. All the above grounds are without prejudice to each other. The Appellant craves for leave to add, amend, vary, omit or substitute any of the aforesaid grounds at any time before or at the time of hearing of the matter with the Income Tax Appellate Tribunal." 3. The assessee company is engaged in providing telecommunications services. The assessee started its commercial operations in AY 2009-10 and is currently engaged in providing National Long Distance ('NLD') as well as International Long Distance ('ILD') Telecom services to its Indian and overseas customers. The Assessee filed the return of income for the present assessment year on 30th November 2012 declaring a total income of Rs. 7,68,....