2024 (8) TMI 882

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....d by the Ward TDS and Addl. Comm. TDS Ghaziabad (hereinafter referred to as 'AO') under Section 271CA and 271C of the Income Tax Act, 1961 (the Act) concerning Assessment Years 2017-18 and 2018-19 (ITA Nos.861 & 862/Del/2023). 2. The grounds of appeal raised by the assessee in ITA No.860/Del/2023 for A.Y. 2017-18 reads as under: 1. "That under the facts and circumstances of the case the learned Assessing order has erred in initiating the proceeding. The initiation of proceedings is arbitrary, unjust, uncalled for illegal and against the provision of the act. 2. That under the facts and in law the learned Additional Commissioner of Income Tax has erred to work out Rs. 35,000/- as penalty, hence the levy of penalty deserv....

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....e the proper opportunity of hearing violating the principles of natural justice. Hence, Commissioner of Income Tax(Appeals) Order is liable to be set aside. 5. The Appellant reserve the right to raise, add, modify or later any other grounds for adjudication of the appeals." 4. The grounds of appeal raised by the assessee in ITA No.862/Del/2023 for A.Y. 2018-19 reads as under: 1. "That under the facts and circumstances of the case the learned Assessing order has erred in initiating the proceeding. The initiation of proceedings is arbitrary, unjust, uncalled for illegal and against the provision of the act. 2. That under the facts and in law the learned Additional Commissioner of Income Tax has erred to work out ....