2024 (5) TMI 766

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ses out of the assessment order under section 144 of the Income Tax Act, 1961 [hereinafter referred as 'the Act'] . 2. The relevant facts as culled from the material on records are as under : 3. Assessee is a private limited company who electronically filed its return of income on 17.10.2018 for A.Y. 2018-19 declaring an income of Rs. 1,42,380/-. The case was selected for scrutiny under CASS for the reason "assessee has made substantial purchases from suppliers who are either Non-Filer(s) or have filed non-business ITR or reflected a substantially lower turnover in ITR as compared to turnover shown in GSTR 1 return". Thereafter, assessment was framed u/s 144 r.w.s 143(3A) & 143(3B) of the Act vide order dated 06.04.2021 and the total inco....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... while passing the impugned order as the Ld. CIT(A) have failed to appreciate the fact that during the period of appeal proceedings the appellant could not reply to the notices issued by the CIT(A) due to the reasons beyond his control and also due to the health issues being faced by the director of the assessee company. 4. That under the facts and circumstances of the case the Ld. CIT(A) has erred in law as much as in fact while passing the impugned order, as the Ld. CIT(A) has upheld the addition made by the Ld. AO in the assessment order dt. 06.04.2021 passed without following the due provisions of law and without having proper jurisdiction. 5. That under the facts and circumstances of the case the Ld. AO has erred in law as much as ....