2022 (9) TMI 1515

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....o the Assessment Year 2011-12. 2. The assessee has raised the revised grounds of appeal: "1. The Ld. CIT(A) has erred in law as well as on facts in confirming an assessment order U/s. 144 of the act. The order deserves annulment. 2. The Ld. CIT(A) has erred in law as well as on facts considering that the Ld. A.O. has erred in not providing reasonable opportunity to the appellant. The order deserves annulment. 3. The Ld. CIT(A) has erred in law as well as on facts in confirming order U/s. 144 passed without properly service of the notice on the appellant. The proceedings being bad in law deserve annulment. 4. The Ld. CIT(A) has erred in law as well as on facts in not confirming providing the material av....

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.... in law as well as on facts in not applying guidelines available U/s. 44AD. The taxability of gross income in full is neither legal nor statutory nor logical. 12. Without prejudice, the income determined needs suitable reduction. 13. Without prejudice the Ld. CIT(A) erred confirming disallowance of expenditure at 100%. The same needs suitable reduction. 14. Without prejudice the Ld. CIT(A) erred in not considering the identical cases to compare his own action. The assessment needs annulment. 15. The appellant craves leave to add/alter/amend and/or substitute any or all grounds of appeal before the actual hearing takes place." 3. The only interconnected issue raised by the assessee is that the Ld. CIT(A....

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.... It is apparent that assessee has preferred not to submit any details regarding such expenditure and is hoping for the best reasonable estimate of income which the assessing officer or the appellate authority or CIT(Appeals) can grant to him. Such course of action is very unfortunate. In present case the income is arising from other sources and not from the business activities. The indulgence in a systematic business activities will definitely lead to incurrence of certain expenditure and in absence of exact quantification of such expenses or reasonable estimates should be made of such expenditure and only the expected reasonable profit should be taxed out of the said business transaction. 5.2 However, this proposition is not corre....