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2022 (7) TMI 1317
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....er the provisions of section 143(1). The demand raised consequent thereof needs to be cancelled on account of non statutory actions of the Ld. A.O. as held by the Hon. ITAT, Calcutta that change of status is not permissible U/s. 143(1). The A.O's actions needs cancellation. 2. The Ld. CIT(A) has erred in law and facts in confirming excess Income-tax payable at normal rate of Rs. 46,486/-. The determination needs deletion. 3. The Ld. CIT(A) has erred in law and facts in confirming excess Income-tax payable at normal rate of Rs. 46,486/- without cogent reason. The determination needs deletion. 4. The Ld. CIT(A) has erred in law and facts in confirming excess Income-tax payable at normal rate of Rs. 46,486/- with....
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....tment in earlier years. The determination needs deletion. 12. Taking into consideration the legal, statutory, factual and administrative aspects, no determination of excess income-tax of Rs. 46,486/- ought to have been confirmed. The same need deletion. 13. Without prejudice, the intimation made is bad in law and deserves annulment. 14. Without prejudice, no adequate, sufficient and reasonable opportunity has been provided at assessment stage. The intimation needs annulment. 15. Without prejudice, no adequate, sufficient and reasonable opportunity has been provided at appellate stage. The intimation needs annulment. 16. Without prejudice, the determination is framed beyond statutory time limit. T....
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....atus as mentioned by assessee in return of income and that shown in the intimation of CPC are the same. As regards the computation of tax and interest u/s 234A, 234B and 234C, the assessee has not shown how the computations by CPC are wrong and not as per law. The grounds of appeal all relating to this single issue are therefore rejected. The assessee however is advised to approach Assessing Officer for rectification u/s 154 if it finds the tax computation wrong. 6. For statistical purpose, the appeal of the assessee is to be treated as dismissed." 4. Before us, the assessee has filed submissions in support of his contention. In the said submission, the assessee has reiterated the submissions made before Ld. CIT(A). The....