2025 (4) TMI 345

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....onforming the order passed of Assessing Officer u/s 154 is bad in law on facts and circumstances of the case. 2. That CIT (A) order is bad In law, as no opportunity of Virtual hearing was not provided, as being asked during the appellate proceeding, which is against principal of natural justice and which makes the order bad in law. 3. That CIT (A) erred in law by not adjudicating the ground of appeal, Including the additional ground of appeal, which is bad in law and makes the CIT (A) order bad in law. 4. The CIT (A) Is erred in law by not providing remand report, whereas AO has asked all documents called upon w.r.t. such remand report, which is bad in law. 5. The CIT (A) Is erred in law by confirming the....

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....961 [the Act, for short] were issued on 07-09-2018 duly served upon the assessee. Subsequently, notices u/s 142(1) of the Act along with questionnaire were issued online on 16-01-2019, 10-04-2019, 03-06-2019, and 30-08- 2019 to the assessee calling for details, submissions and explanations. 5. This case was transferred u/s 127 of Act, 1961, to the office of DCIT, Special Range 12, Delhi through order passed by PCIT-12, Delhi. Accordingly, notices u/s 142(1) along with questionnaire were issued online on 05-11-2019 and 26-11-2019 calling for details. The Assessee submitted replies from time to time. 6. In the course of assessment proceedings, the AO found that the assessee received a sum of Rs.35,03,43,665/- from one M/s Alpha Radios a....

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....ady produced by assessee during the assessment proceedings. 11. The ld AR further stated that the CIT(A) erred in law by confirming the rectification order u/s 154, on the ground that this issue requires verification of facts with respect to provisions of law and revenue recognition/ expenses policy of appellant, therefore, it cannot be said that this is a mistake apparent from record and accordingly the appeal was dismissed. 12. It is the say of ld AR that the ld. CIT(A) further did not adjudicate the grounds raised by assessee including the additional ground no.9, which is related to assessment. The CIT(A) held that these grounds which are raised do not pertain to rectification order passed u/s 154 and liable to be dismissed. 13.....