2024 (12) TMI 1594

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....e was non compliance on the part of the assessee to the various notices issued by him and thereby erred in confirming the addition of Rs. 1,62,79,432/- made by the learned A.O. 2] The assessee submits that there was a reasonable cause on its part for the non compliance to the notices issued by the learned CIT(A) and accordingly, requests for one more opportunity to present its case before the learned CIT(A). 3] The assessee submits that it had not received any physical notice from the office of the ld. CIT(A) and since he is not very well conversant with e- mails and computer, the notices received through portal / mail were not looked into and hence, there was non compliance on the part of the assessee to the notices issue....

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....CASS for scrutiny and notice u/s 143(2) was issued by the Income Tax Officer, Ward-2(1), Jalgaon on 03.07.2017. Further, notice u/s 142(1) was issued by Income Tax Officer, Ward-2(1), Jalgaon and the assessee filed the reply on 03.08.2018 and 14.09.2018, as the jurisdiction over the case lies with Income Tax Officer, Ward-2(2), Jalgaon, the case was received on transfer from the Income Tax Officer-2(1), Jalgaon vide letter dated 14.07.2018, being change in incumbent notice u/s 142(1) r.w.s. 129 was issued on 07.05.2018. Further again notice No. ITBA/AST/F/142(1)/2018-19/1010755955(1) dated 22.10.2018 was issued to the assessee along with questionnaire and the assessee filed its reply vide letter dated 25.10.2018. During the course of assess....

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....assessee is [email protected] and due to this reason, the assessee was unaware with any of the hearing notices issued by Ld. CIT(A)/NFAC. Ld. AR also submitted before the Bench that even otherwise also proper opportunity of hearing was not allowed to the assessee, since the last three notices were issued in a very short span of 13 days. Accordingly, it was requested before the Bench that one opportunity may kindly be provided to the assessee so that he can submit evidences in support of grounds of appeal before Ld. CIT(A)/NFAC. 6. Ld. DR appearing from the side of the Revenue supported the orders passed by the subordinate authorities and requested to confirm the same. 7. We have heard Ld. Counsels from both the sides and peruse....