2022 (4) TMI 276

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....Ld. CIT (A) is bad in law and against the principles of natural justice. 2. That the Ld. CIT (A) has erred by confirming the addition of Rs. 6,95,988/- without appreciating the facts of the case, provisions of law and submissions of the appellant. 3. That the ld. CIT (A) has erred by stating that the income of Rs. 1,95,988/- as reflected in Form 26AS whereas no such income is reflected in Form neither 26AS nor it was credited to the books of account of the assessee during the year. 4. That the Id. CIT (A) has erred by completely ignoring the ground that lastly the case was fixed for 13,12.2018 but the assessment order was passed on 12/12/2018 which is unjustified and bad in law. 5. That the ld. CIT (A) ha....

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....tted on 08.02.2021 through e-filing website. 12. That the Id. CIT (A) has erred by completely ignoring the ground that whether assessment order is passed u/s 143(3)/147 or 144/147 of The Income tax act, 1961 as on the assessment order section 144/147 is written and on the demand notice section 143(3)/147 is written. 13. That the Ld. CIT(A) has erred by passing the appellate order on 28.07.2021 without proving an opportunity to the assessee as there was a gap of more than five months 20 days between the date of last hearing i.e. 08.02.2021 and the date of order i.e. 28/07/2021 which is not justified and bad in law. 14. In view of the facts and circumstances of the case the appellant prays that the additions may kin....

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....t was framed at the back of the assessee, disregarding the principles of natural justice. Learned counsel submitted that the assessee was not given adequate opportunity to effectively represent her case by the Assessing Authority. Therefore, the learned counsel prayed that impugned order may be set aside. 4. On the contrary, learned DR opposed the submissions and supported the orders of the authorities below. However, he fairly submitted that the Revenue would have no objection if the matter is restored to the Assessing officer for decision afresh. 5. I have heard rival submissions and perused the material available on record. From the record it is seen that the Assessing Officer has not recorded in the assessment order that the reaso....