2025 (5) TMI 1864

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....6 are as follows: "1. That on the facts and circumstances of the case and in law, the assessment order dated 19.09.2022 passed by National Faceless Assessment Centre ("NFAC or AO") is perverse and erroneous order, passed in violation of principles of natural justice hence, liable to be quashed. 2. That on the facts and circumstances of the case the assessment order is illegal and bad in law as the same has been passed without issuing a valid show cause notice or a draft order as mandated under section 144B of the Act. 3. That the CIT(A)/National Faceless Appeal Centre has erred in upholding the addition made by AO amounting to Rs. 15,00,000/- treating the agricultural income as income from other sources. 4. That on the facts and ....

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....absence of any agreement in between the assessee and the actual owners of agricultural lands and also in absence of evidence regarding sales of agricultural crops and corresponding J Forms . 6. Before the tribunal the Ld. AR of the assessee filed fresh documentary evidences along with an application under Rule - 27 of ITAT Rules 63, consisting of purchase invoices of one Jindal Trading Company along with copies of ledger A/c of the assessee in its books of accounts, and evidence from another Gholia Traders, as evidence to whom agricultural produce has been sold by the assessee and other documents relating to expenditure incurred in carrying out of agricultural activities. 7. The Ld. AR submitted that the e proceeding portal was closed on ....