2022 (3) TMI 1179

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.... M/s. Jagdama Steel Corporation and Supreme Contractors. Assessee electronically filed his return of income for A.Y. 2012-13 on 24.09.2012 declaring total income of Rs. 5,50,000/-. The case was selected for scrutiny and thereafter assessment was framed under section 143(3) of the Act vide order dated 17.03.2015 and the total income was determined at Rs. 87,81,322/-. Aggrieved by the order of AO, assessee carried the matter before CIT(A) who vide order dated 28.08.2018 in Appeal No.31/17-18/110/15-16 dismissed the appeal of the assessee. Aggrieved by the order of CIT(A), assessee is now in appeal and has raised the following grounds: "1. (a) That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law a....

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....and not in a position to present the case. 3. That having regard to the facts and circumstances of the case, action of Ld. CIT(A) is had in law in observing the wrong fact that surrender made by assessee during the course of assessment proceedings establishes the culprit nature whereas the same was made to buy mental peace. 4. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in not reversing the action of Ld. AO in charging interest u/s 234B, 234C and 234D of the Income Tax Act, 1961. 5. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each....

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....98,990/- and worked out the profit @ Rs. 87,59,848/-. He thereafter granted credit of Rs. 5,28,526/- shown by the assessee as his income and thus made an addition the differential amount of Rs. 82,31,322/-. Aggrieved by the order of AO, assessee carried the matter before CIT(A) who vide order dated 28.08.2018 in Appeal No.31/17-18/110/15-16 upheld the action of AO. Aggrieved by the order of CIT(A), assessee is before us. 5. Before us, Learned AR reiterated the submissions made before the lower authorities and further submitted that though in the show cause notice issued by AO, AO asked the assessee to show-cause as to why the profit not be estimated at 8%, but thereafter AO without given any further notice, estimated the profit @15%. He ....