2022 (4) TMI 150
X X X X Extracts X X X X
X X X X Extracts X X X X
....ons, i.e., on 03.03.2021, 27.07.2021, 07.10.2021 and 22.12.2021, however, every time the assessee remained absent. Despite issuance of notice repeatedly, not only through postal mode, but also through the office of learned Departmental Representative. In spite of the fact that the proceeding of 22nd December, 2021, adjourning the case to 14th March, 2022 was uploaded in the official website, still, the assessee remained absent when the appeal was called for hearing today, i.e., 14.03.2022. These facts reveal a complete lack of interest of the assessee to pursue the present appeal. Considering assessee's lack of interest and also the fact that the appeal is pending since last five years, we proceed to dispose of the appeal ex-parte qua t....
X X X X Extracts X X X X
X X X X Extracts X X X X
...., to the best of his judgment. However, before proceeding further, he issued a show-cause-notice to the assessee through mail, not only to the assessee, but to his Directors and Auditors. Still, there was no compliance by the assessee. 5. Finding no other alternative, the Assessing Officer proceeded to complete the assessment under section 144/143(3) of the Act to the best of his judgment by making number of additions aggregating to Rs. 21,76,39,374/-, resulting in determination of total income of Rs. 23,38,81,650/-. Against the assessment order so passed, assessee preferred an appeal before learned Commissioner (Appeals). After considering the submissions of the assessee, learned Commissioner (Appeals), deleted the additions made by the A....
X X X X Extracts X X X X
X X X X Extracts X X X X
....(1)/143(3) with detailed questionnaire seeking clarification from the assessee. However, it is a fact on record that neither did the assessee attend the assessment proceeding, nor furnished any reply to the queries raised by the Assessing Officer. Therefore, the Assessing Officer proceeded to complete the assessment under section 144 of the Act to the best of his judgment, based on materials available on record. As it appears, before learned first appellate authority, the assessee not only furnished detailed submission contesting the additions made by the Assessing Officer, but also furnished fresh evidences, which the Assessing Officer never had opportunity to examine. Though, as per the mandate of Rule 46A(3), learned Commissioner (Appeal....