2024 (12) TMI 1063

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....of the case, the order passed by the Additional/ Joint Commissioner of Income Tax, Appeal(Addl/JCIT (A)-2, Mumbai) is bad both in the eye of law and on facts. 2. On the facts and circumstances of the case, the learned Addl/JCIT(A) has erred both on facts and in law in confirming the adjustment of Rs. 1,88,11,663/- made by the AO(CPC)in the intimation order passed under section 143(1) of the Act. 3. On the facts and circumstances of the case, the learned Addl/JCIT(A) has erred both on facts and in law in confirming the abovesaid adjustment despite the fact that the same has been made by the AO(CPC) by exercising its powers beyond the scope of section 143(1) of the Income Tax Act and does not fall in any of the subclauses of....

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....e above and in the alternative, the learned Addl/JCIT(A) has erred, both on facts and in law in rejecting the contention of the assessee that AO(CPC) has brought gross receipts to tax which is against the basic principles of law where only the real income which is determined after deducting expenses from gross receipts can be brought to tax. 6. That the appellant craves leave to add, amend or alter any of the grounds of appeal." 3. Briefly stated, the facts of the case are that the assessee is a resident Charitable Trust registered u/s 12AA of the Income-tax Act, 1961 [the Act, for short]. The assessee is running a hospital for treating patients with mental diseases and also runs various health care centers. 4. The return of ....