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2022 (9) TMI 246
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....in upholding the order of the learned assessing officer in wrongly assuming jurisdiction under section 148 of the Income tax Act, 1961 and in also completing the assessment under section 144 of the said Act. 2. That on the facts and in the circumstances of the petitioner's case, the learned CIT(A) erred in law and on facts in completely ignoring the fact that a) first two notices issued under section 143(2) both on 01-11-2018 for initiating the assessment proceedings and after that b) various notices issued under section 142(1), all these notices wherever sent by post were sent on some unknown address of Ambala not related to the petitioner at all. Even the show cause issued on 11-12-2018 was wrongly sent on some unkno....
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....y the learned assessing officer at the threshold itself, which the learned CIT(A) failed to take notice of. 6. That on the facts and in the circumstances of the petitioner's case, the learned CIT(A) erred in law and on facts in arbitrarily applying the provisions contained in section 69A of the Income tax Act, 1961 and exceeding his mandate in law and specially to circumvent that such cash credits were not found in the books of account of the petitioner. 7. That on the facts and in the circumstances of the petitioner's case, the learned CIT(A) erred in law and on facts in upholding the order of the learned assessing officer, in confirming the additions of Rs.1043000 allegedly on the ground of unexplained cash depos....
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....e the facts that the AO recorded the contradictory facts. The assessee was not provided sufficient opportunities to represent his case for re-opening of the assessment, was not in accordance with law. It was stated before the lower authorities that the account being joint with the wife of the assessee hence, the entire amount should not have been attributed. 7. On the contrary, Ld. Sr. DR opposed the submissions and supported the orders of the authorities below. 8. I have heard Ld. Authorized representatives of the parties and perused the material available on record and gone through the orders of the authorities below. Before the AO, there was no representation on behalf of the assessee. It is recorded by the AO that various opportun....