2024 (8) TMI 745

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....the IT Act, 1961 and upholding the additions of Rs. 1,25,28,102 made by the Ld.AO u/s 68 of the I.T.Act. 2. That in the facts and circumstances of the case Ld. CIT(A)- NFAC has erred in passing the ex parte order on the ground that no reply / submissions made of the hearing notices served on the email. 3. That in the facts and circumstances of the case the Ld. CIT(A) - NFAC has erred in not issuing and serving any physical/ by speed post notice of hearing before passing the impugned ex parte order and also failed to serve the final order physically/ by speed post 4. That in the facts and circumstances of the case the reopening the assessment as per notice u/s 148 dt. 29.03.2019 is time barred i.e. beyond four years as the original ass....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ssessment u/s 144/ 147 of the IT Act even when all the details were submitted and are available on the e portal. 10. That in the facts and circumstances of the case the assessment framed u/s 144/ 147 of the IT Act is bad in law as no DIN has been generated. The DIN generated is for the Asstt. Order u/s 143(3)/ 147 of the IT Act. 11. That in the facts and circumstances of the case the Ld. A.O. has erred in making addition of Rs. 1,25,28,102 on account of accommodation entry in the form of bogus expenses u/s 68 of the Income Tax Act while framing the assessment u/s 144/ 147 of the I.T. Act. 12. That in the facts and circumstances of the case the ld. AO has erred in making addition of Rs. 1,25,28,102 on the ground that "ledger account of....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nt craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other 2. Facts, in brief, are that for A.Y. 2012-13 the Assessing Officer had received information from DDIT (Inv.)-I, Faridabad to the effect that assessee company had made payment of Rs. 1,25,28,000/- primarily in the form of bogus expenses to bogus concern viz. Softech Enterprises. Therefore, the case was re-opened u/s 147 of the Act and statutory notices were issued accordingly. In response to notice issued u/s 148 of the act, the assessee filed return declaring total income at Rs. 1,36,562/-. During assessment proceedings the assessee did not respond to statutory notices with q....