2025 (5) TMI 1309

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....ter referring as Act, dated 08.11.2021. 2. Assessee has raised following grounds of appeal:- 1. On the facts and in the circumstances of the case and in law, the Hon'ble CTT(A) has erred in not appreciating that even while disposing of the appeal ex parte, the Hon'ble CIT(A) was duty bound to dispose of the appeal on merits. Accordingly, the Order passed by the Hon'ble CIT(A) without going through the detailed statement of facts, grounds of appeal and the submissions dated 2 February 2012 and 9 January 2025 cannot be sustained. 2. On the facts and in the circumstances of the cave and in law, the Hon'ble CIT(A) errad by upholding the order passed by the leamed AO ('assessment order) in relation to tra....

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....ht to have been granted due credit of TDS, resulting in consequential refund along with interest. 8. On the facts and in the circumstances of the case and in law, the Hon'ble CIT(A) failed to appreciate that the learned AO has erred in initiating penalty proceedings under section 270A of the Act. The above grounds are Independent and without prejudice to one another. The Appellant cravess leave to add, amend, vary, omit or substitute any of the aforesaid grounds of appeal at any time before or at the time of hearing of appeal, so as to enable the Hon'ble Income-tax Appellate Tribunal to decide this appeal according to law. 3. At the outset Ld. Counsel for the assessee stated that the impugned order is ex- parte ....