2023 (1) TMI 19

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.... And Shri Saksham Agarwal, C. A.; For the Department : Shri Toufel Tahir, Sr. D. R.; ORDER PER SAKTIJIT DEY , J. M. : 1. This is an appeal by the assessee against the order dated 1.08.2019 of learned Commissioner of Income Tax (Appeals)-10 [hereinafter referred to as CIT (Appeals)] New Delhi, for assessment year 2010-11. 2. Grounds raised by the assessee are as under:- "1. ....

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....7 to 151 have not been met. 2. That in any case and in any view of the matter, action of Ld. CIT(A) in confirming the action of Ld. AO in framing the impugned reassessment order u/s 143(3)/147, is bad in law and against the facts and circumstances of the case; 3. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming ....

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....rred in law and on facts in not reversing the action of Ld. AO in charging interest u/s 234B and 234C of Income Tax Act, 1961." 3. However, at the time of hearing, Dr. Rakesh Gupta, ld. Counsel appearing for the assessee submitted that he will be arguing only on the merits of the addition of Rs.41,83,821/- made under section 69C of the Income Tax Act, 1961 (the Act) and not on other grounds. Ac....

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.....41,83,821/- by invoking the provisions of section 69C of the Act. Though, the assessee contested the aforesaid addition before learned CIT (Appeals) however, he was un-successful. 5. Before me, learned Counsel appearing for the assessee submitted that in assessee's own case in some other assessment years, in respect of purchases made from some of the very same parties, the Assessing Officer ha....