2019 (9) TMI 1708

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....961 (hereinafter referred to as "the Act") dated 03/02/2014 relevant to Assessment Years (A.Y.) 2011-12. The assessee has raised the following grounds of appeal: 1. The Ld. CIT(A) has erred in law as well as on facts in confirming an assessment order passed U/s. 144 of the act. The order deserves annulment. 2. The Ld. CIT(A) has erred in law as well as on facts in not considering that no reasonable opportunity was provided to the appellant by the Ld. A.O. The order deserves annulment. 3. The Ld. CIT(A) has erred in law as well as on facts in confirming passing of order U/s. 144 without properly service of the notice on the appellant. The proceedings being bad in law deserve annulment. 4. The Ld. CIT(A)....

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....le to the appellant under the various provisions of the Act. 11. Without prejudice, the Ld. CIT(A) has erred 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 grounds of appeal before the actual hearing....

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....ion of the assessee by observing that the income was offered to tax under the head income from other sources and therefore the onus lies on the assessee to justify the expenses claimed against such income based on the documentary evidence. But the assessee failed to provide any documentary evidence in support of the expenses of Rs.5,19,863.00. Accordingly, the learned CIT (A) rejected the claim of the assessee. However the learned CIT (A) was pleased to delete the addition made by the AO to the extent of the income offered by the assessee for Rs.1,52,620.00 by observing that the impugned addition is leading to double addition. Thus, the learned CIT (A) confirmed the order of the AO in part. Being aggrieved by the order of the learned CIT (A....