2024 (5) TMI 1474

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ndent : Mr.Vipul Aggarwal, SSC with Mr. Gibran Naushad, Ms. Sakshi Shariwal, Advs. ORDER 1. This appeal is directed against the order of the Income Tax Appellate Tribunal ["ITAT"] dated 19 January 2022 and posits the following questions for our consideration. "(i) Whether the authorities below (Ld. AO, Ld. CIT and Ld. ITAT) have not committed serious error and gross illegality in as....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....circumstances of the case and admittedly belonging to appellant's mother, appellant's wife, and appellant's son as per records of Income Tax department? (iv) Whether in the facts and circumstances of the case the oral admission about ownership of bank accounts in question is false and illegal viewed in the light of totality of facts and circumstances and particularly in view of the fact t....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....for o buy peace" is not with free consent and is instead under compulsion of circumstances and no tax can be levied based thereon? (vi) Whether Ld. CIT and Ld. ITAT have lent undue and unwarranted support to Ld. AO by not taking cognizance of grossly illegal proceedings and manner of conducting as an assessing authority and have thereby not only caused harassment and injustice to the appe....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... without affording any hearing, opportunity to explain being in violation of legal and constitutional principal of natural justice. (ix) Whether Ld. ITO has not failed to exercise jurisdiction and powers vested in it under section 254 (2) of the Income Tax Act by refusing vide order dated 17.03.2023 to entertain M.A. No. 158 of 2022 and refused to rectify the impugned order dated 19.01.20....