2025 (5) TMI 600

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....rdingly, the order is bad in law and ought to be quashed. 2. The additions of Rs. 17,61,000 made by the Assessing Officer and sustained by the learned NFAC is purely based on surmises, conjecture, and presumptions and therefore the same deserves to be deleted. 3. The learned NFAC grossly erred in confirming the order framed by the Assessing Officer under section 143(3) in determining the total income at Rs. 25,98,020 including computing the taxable income at Rs. 17,61,000 under section 69A r.w.s Section 115BBE of the Act as against Rs. 8,37,020 returned under regular provisions of the Act by the appellant. 4. The learned NFAC ought to have appreciated that the Assessing Officer ignored the business model of the Ap....

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....of income and taxes have been paid on the same by the appellant. e) The learned NFAC has erred in confirming the order of the Assessing Officer ignoring the position of law that provisions of section 69A cannot be applied in respect of income from a source which has already been taxed which would amount to double taxation. f) The learned NFAC has failed to appreciate that all the purchases and sales are fully vouched and no defects in the quantitative details of stock register maintained by the appellant have been found and, therefore, the confirmation of addition of Rs. 17,61,000 is against the facts and circumstances of the case. g) The learned NFAC has failed to appreciate that the Assessing Officer having not ....

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.... the order of the Assessing Officer in levying interest under section 234B of the Act at Rs. 4,48,896. The appellant denies the said --- liability of interest under section 234B. Ground no. 7 - Levy of interest under section 234C The learned NFAC erred in upholding the order of the Assessing Officer in levying interest under section 234C of the Act at Rs. 4,586. The appellant denies the said liability of interest under section 234C. General 8. The Assessing Officer erred in initiating penalty proceedings under section 271AAC(1) of the Act. 9. Each one of the above grounds of appeal is without prejudice to the other. 10. The appellant reserves the right to add, alter, vary, omit or substi....