2016 (8) TMI 1587

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....horities below in so far as it is against the Appellant, is opposed to law, weight of evidence, natural justice, probabilities, facts and circumstances of the Appellant's case. 2. The appellant denies itself to be assessed on a sum of Rs. 5,66,90,094/- as against a sum of Rs. 1,05,35,680/- as declared by the appellant under the facts and circumstances of the case. 3. The action of the CIT-A in dismissing the appeal on the ground of non-payment of admitted taxes when the appellant had paid the taxes as per the return filed on 09.04.2008 is against the facts of the case and against all known canons of reasonableness and natural justice and patently illegal. 4. The order of the authorities below is bad in law as ....

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.... PRAYER FOR ADMITTING ADDITIONAL GROUNDS OF APPEAL WHICH WERE NOT ORIGINALLY URGED BEFORE THE CIT-A The assessee appellant begs to submit the under mentioned additional grounds of appeal which were not urged specifically in the original grounds of appeal filed before the learned CIT(A). These grounds do not involve any investigation of any facts otherwise on the record of the department and are also pure questions of law, which goes into the very root of the matter of jurisdiction and validity of the assessment and therefore, it is prayed that the additional grounds may kindly be admitted and disposed off on merits for the advancement of substantial cause of justice. Reliance is placed on the decision of the Hon'ble Apex Co....

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....he assessment was framed. 3. Against the assessment order, the assessee filed an appeal before the CIT(Appeals) and the CIT(Appeals) has raised the objection that the assessee had not paid the tax on the admitted return of income; whereas according to the assessee, it has already paid the tax on the admitted return of income and since revised return filed by the assessee was not accepted by the AO, there was no question of payment of tax on the income declared in the revised return. The CIT(Appeals) was not convinced with this argument and the CIT(Appeals) has dismissed the appeal of the assessee, without dealing with the issues on merit. Now the assessee is before the Tribunal and reiterated its contentions. 4. Having carefully exami....