2025 (6) TMI 1115
X X X X Extracts X X X X
X X X X Extracts X X X X
.... Sr. DR ORDER PER SONJOY SARMA, JUDICIAL MEMBER: The present appeal has been preferred by the assessee against an order dated 22.09.2023 of the National Faceless Appeal Centre [hereinafter referred to as 'CIT(A)'] passed u/s 250 of the Income Tax Act (hereinafter referred to as the 'Act'). 2. Brief facts of the case are that the assessee is an individual and running a petrol pump under the p....
X X X X Extracts X X X X
X X X X Extracts X X X X
....91,879/- claimed under the heads 'festival expenses, festival lighting expenses and puja expenses'. v. Rs. 2,74,500/- claimed as tank lorry expenses. Thus the total addition of Rs. 1,04,89,312/- was made leading to an assessed income of Rs. 1,38,98,360/-. 3. Aggrieved by the above order, the assessee filed an appeal before the ld. CIT(A). However, the ld. CIT(A) while passing the appellate ord....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... Moreover, he submitted that while passing the impugned order, the books of account of the assessee were not rejected as and when the assessee had submitted all necessary documents such as cash book in order to substantiate the claim of cash deposits. However, these facts have never been considered by the Assessing Officer nor by the ld. CIT(A) at the time of passing of the orders. Therefore, the ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....CIT(A), the ld. CIT(A) changed the section of addition from section 68 to section 69A without issuing any notice to the assessee and without providing any opportunity to rebut or explain. We note that the action of the ld. CIT(A) is totally contrary to the principles of natural justice. In such circumstances, we deem it necessary that the entire matter needs to be remanded back to the file of the ....