2022 (7) TMI 219

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....rred to as the 'Act'). The assessee in this appeal has taken the following grounds of appeal: "1. That on the facts and in the circumstances of the case, the learned Commissioner of Income Tax (Appeals) erred in upholding the DCIT's assessment on a total income of Rs 37,03,780/- against the Income of Rs 13,017,18/- (Rs 9,06,444/- as reflected in the Assessment Order and Rs.3,95,274/- accepted by the Appellant itself.) 2. That on the facts and in the circumstances of the case, the learned CIT (A) erred in upholding the addition of Rs.24,02,058/- on account of disallowance u/s 40(a)(ia) of the Income Tax Act 3. That on the facts and in the circumstances of the case, the learned CIT(A) failed to appreciate that t....

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....ant as Rs.18,68,745/- as against actual tax paid by the appellant Rs.29,91,680 (Advance Tax Rs.5,50,000/- and Regular Assessment Tax Rs.24.41,680/-). 8 That on the facts and in the circumstances of the case, the learned CIT(A) erred in disregarding the fact that the appellant had duly deducted tax on Rs. 50,000 paid to Shri Puran Kumar Roy and deposited the same before the due date of filing return u/s 139(1). 9. That the appellant craves leave to add, alter and/or amend the grounds of appeal at the time of hearing." 2. Ground No.1 - Ground No.1 is general in nature. The assessee has raised all the issues collectively in this ground, whereas the assessee in subsequent grounds has contested each of the grounds separately....