2025 (6) TMI 1856

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....nstant appeal before the Tribunal. The assessee has submitted an application for condonation of such delay explaining reasons for the delay. We, after perusing the petition made in the application, satisfy that there were bona fide and sufficient reasons for such delay. We, therefore, condone the delay and admit this appeal for adjudication. 3. Brief facts of the case are that the assessee company filed its return of income for the assessment year 2017-18 by declaring total income as Nil. Subsequently, the case of the assessee was selected for limited scrutiny under CASS followed by issuing of notices u/s 142(1) and 143(2) of the Act to the assessee and the assessee complied to the notices. During the assessment proceedings, the assessee....

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....ssessee submitted sufficient documents in order to substantiate the claim and the ld. CIT(A) confirmed the addition without considering the documents furnished by the assessee. The ld. AR stated that the disallowance u/s 14A amounting to Rs. 1,88,254/- is also bad in law as the ld. CIT(A) confirmed the addition without considering the fact that the assessee had not earned any exempt income during the relevant assessment year and the addition u/s 14A cannot be made without having any exempt income earned. The ld. AR also stated that the issue of enhancement of income at Rs. 3,52,22,603/- as unexplained expenditure u/s 69C by the ld. CIT(A), is also bad in law and not justified as the ld. CIT(A) failed to issue any statutory show-cause notice....