TaxTMI 
TaxTMI 
2024 (11) TMI 232
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....on order. 1.1 We will take the A.Y.2013-14 as a lead case. The assessee has raised following Grounds of appeal : "1) The learned CIT(A) erred in dismissing the appeal of the assessee ex-parte on the ground that there was non compliance on the part of the assessee to the various notices issued by him and thereby erred in confirming the addition of Rs. 19,43,14,369/- made by the learned A.O. 2) The assessee submits that there was a reasonable cause on its part for the non compliance to the notices issued by the learned CIT(A) and accordingly, requests for one more opportunity to present its case before the learned CIT(A). 3) The assessee submits that the notices were issued by the learned CIT(A) on the e-mail ID which was not being use....
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....notices send by ld.CIT(A). Ld.AR submitted that practically Assessee Company has closed down its business, therefore, there is no one to receive or check the Emails. Ld.AR invited our attention to the copies of the GST Returns filed at page no.49 to 101 of the paper book to demonstrate that as per GST Returns, turnover of the assessee is Nil from F.Y.2019-20. Ld.AR also invited our attention to copies of the Return of Income filed by the assessee for A.Y.2020-21 onwards to demonstrate that actually there were no business activities. Ld.AR submitted that since most of the Assessee's employees have left, the Emails have not been checked. Ld.AR submitted that there was no malafide intention in not complying notices issued by ld.CIT(A). Ld.AR s....
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....0(4) of the Act. Further Section 250(6) of the Act obliges the CIT(A) to dispose of an appeal in writing after stating the points for determination and then render a decision on each of the points which arise for consideration with reasons in support. Section 251(1)(a) and (b) of the Act provide that while disposing of appeal the CIT(A) would have the power to confirm, reduce, enhance or annul an assessment and/or penalty. Besides Explanation to sub-section (2) of Section 251 of the Act also makes it clear that while considering the appeal, the CIT(A) would be entitled to consider and decide any issue arising in the proceedings before him in appeal filed for its consideration, even if the issue is not raised by the appellant in its appeal....