2025 (5) TMI 596

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....ear ('A.Y.' for short) 2014-15. 2. The assessee has raised the following grounds of appeal: "1. On the facts and in the circumstances of the case, and in law, the reassessment proceedings u/s 147/148 are bad in law, inasmuch as the mandate of Section 147 of the Act was not satisfied. The appellant, therefore, prays that the assessment order u/s.147 read with Section 144B of the Act, dated 30.03.2022 be quashed. 2. On the facts and in the circumstances of the case, and in law, the Ld. CIT(A) erred in upholding the assessment order even though the same was passed in gross violation of basic principles of natural justice. The appellant, therefore, submits that the assessment order u/s.147 is bad in law, and therefore, pray....

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.... to the notice u/s. 148, declaring the same income as the returned income. The ld. AO issued notice u/s. 143(2) and 142(1) of the Act. As the assessee failed to furnish the complete details of form 16A/26AS of some of the deductee inspite of several opportunities, the ld. AO disallowed 30% of the total expenditure towards labour payment amounting to Rs. 46,24,322/- for which it was alleged that the assessee has failed to deduct TDS, thereby making an addition of the same to the business income of the assessee. The ld. AO passed the assessment order u/s. 147 r.w.s. 144B of the Act, dated 30.03.2022, determining total income at Rs. 31,99,167/-, after making an addition/disallowance of Rs. 13,87,297/-. 4. Aggrieved the assessee was in appea....