2021 (7) TMI 1406

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....ounds of appeal in these appeals with only change in figures and the grounds for the AY 2012-13 are as follows:- "1. The orders of the authorities below in so far as they are against the appellant, are opposed to law, equity, weight of evidence, probabilities, facts and circumstances of the case. 2. The order of the learned CIT[A] is void-ab-initio and bad in law as the same is passed on erroneous appreciation of facts and law and further, in violation of the principles of natural justice warranting it to be cancelled as void-ab-initio. 3. The learned CIT[A] is not justified in dismissing the appeal in-limine on the ground that the tax on the income returned in the return filed in response to notice u/s.153C of th....

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....he income and there was not any incriminating materials pointing out any undisclosed income and consequently, the assumption of jurisdiction u/s.153C of the Act, is bad in law for the assessment year under appeal having regard to the ratio of the decision of the Hon'ble jurisdictional High Court in the case of IBC KNOWLEDGE PARK P. LTD., reported in 385 ITR 346 [Kar]. 5. Without prejudice to the above, the learned CIT[A] is not justified in upholding the completion of the assessment u/s.144 of the Act under the facts and in the circumstances of the appellant's case, in as much as, the appellant's husband was appearing before the learned A.O. only to submit and emphasis again and again that the A.O. did not have jurisdic....