2024 (7) TMI 40

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.... the "Act), pertaining to the assessment year 2011-12. The assessee has raised following grounds of appeal: "1. The order passed by the Learned Commissioner of Income Tax (Appeals)-28 ("Ld. CIT(A)") under Section 250 of the Act is bad in law and on the facts and circumstances of the case. 2. The Ld. CIT(A) has erred in law and on the facts and circumstances of the case in upholding the order passed by the Ld. Assessing Officer ("Ld. AO") thereby levying penalty of Rs. 18,80,120 u/s 271(1)(c) of the Act. 3. The Ld. CIT(A) has erred in law and on the facts and circumstances of the case in upholding the order passed by the Ld. AO thereby holding that the appellant has furnished inaccurate particulars of income withou....

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....assed without appreciating the facts and circumstances of the case and has been passed mechanically without application of mind. The Ld. CIT(A) has chosen to pass the impugned order in utter ignorance of the submissions made by the appellant. 8. The order passed by the Ld. CIT(A) is bad in law and liable to be set aside as the same has been passed by incorrect application of law and judicial precedents. The impugned order has been passed by the Ld. CIT(A) in utter ignorance of the principles of judicial discipline. 9. The above grounds of appeals are independent and without prejudice to one another. 10. The appellant may be allowed to add/withdraw or amend any ground of appeal at the time of hearing." 2. The so....