2025 (5) TMI 1080

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....the Ld. CIT(A) is bad in law. 2. That on facts and circumstances of the case, Ld. CIT(A) grossly erred in considering deposits of Rs. 84,33,500/- as unexplained cash and added to the income of the appellant u/s. 69 of the Income Tax Act. That the appellant reserves its right to add, alter, amend or withdraw any ground of appeal either before or at the time of hearing of this appeal. 2. The Ld. Counsel for the assessee submits that assessee has filed additional legal grounds of appeal with a prayer to admit the additional grounds. He placed reliance on the decision of the Hon'ble Supreme Court in the case of National Thermal Power Ltd. Vs. CIT (229 ITR 383 and Jute Corporation of India Ltd. vs. CIT 187 ITR 688 (SC). 3....

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.... If so, the date of filing the said return - - - - 5.1 On perusing the Column No. 8, as aforesaid, it revealed that nothing was written against the Column No. 8 of the Reasons Recorded in the aforesaid Form. Hence, Ld. Counsel for the assessee submitted that this is a wrong information recorded in as much as he submitted that income tax return was duly filed, a copy of which is attached with the Paper Book at Page No. 12, thus, he submitted that there is no application of mind by the AO while recording the reasons and accordingly, the assessment is liable to be quashed on this account. In this regard, he referred the decision of the Hon'ble Delhi High Court in the case of PCIT vs. RMG Polyvinyl (I) Ltd. [2017] 83 taxmann.com ....