2024 (11) TMI 367

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....l Faceless Appeal Center (NFAC) is arbitrary. biased and bad in law and in facts and circumstances of the case in so far as it confirms the additions made by the Assessing Officer. (2) That the Learned National Faceless Appeal Center has grossly erred in not condoning the delay in filing the appeal despite the assessee having a reasonable cause in late filing of appeal before NFAC. (3) In law and facts of the case, the Learned National Faceless Appeal Center has grossly erred in not condoning the delay in filing the Appeal of 35 days despite the Assessee submitting in response to deficiency letter issued by the NFAC that delay in filing of appeal was on account of initial advice of a senior counsel to file a writ before th....

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....and not the Faceless Assessment Unit contrary to the provisions of section 144B and section 151A of the Act is illegal bad in law. (9) In law and facts of the case the reopening of assessment is illegal and bad in law for the reason that the reopening of assessment has been done mechanically without independent application of mind on receipt of information from DGGI, Gurugram (GST) that the Assessee had made sale transactions with one of the entities investigated by DGGI, Gurugram (GST). (10) That the Learned National Faceless Appeal Center has grossly erred in confirming the action of the AO in making trading addition of Rs. 6,97,39,038/- for purchases made from M/s RCI Industries and Technologies Limited as business inco....

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....f the assessee in making the addition of Rs.3,46,82,091/- under section 68 r.w.s. 115BBE of the Act for receipt of sales consideration from M/s RCI Industries and Technologies Limited for sales made to it as unexplained credit ignoring the fact that the addition amounts to double addition as the sales for the above amount had been declared as income by the Assessee in its Audited Profit and Loss account which addition is unsustainable in law and facts of the case. 14) That the appellant craves leave to add, alter or delete the above grounds of appeal at the time of hearing." 3. Brief facts of the case are that, an assessment order came to be passed on 18/03/2024 u/s 147 read with Section 144B of the Income Tax Act, 1961 ('Act' f....