2025 (8) TMI 190

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....o as the 'Act'). 2. The appeal is time-barred by 324 days. An application for condonation of delay has been filed, which is also supported with the affidavit of Shri Subhash Sharma, the director of the assessee company, wherein, it has been pleaded that the impugned order of the CIT(A) was passed on 01.09.2023 but the order was communicated to the assessee on 03.09.2024. Immediately, the assessee engaged an authorized representative and filed the appeal. The ld. AR further stated that the notice and also the impugned order were not duly served upon the assessee due to mismatch of email address which was provided in Form 35. Therefore, the assessee was not aware of the passing of the impugned order and as and when the assessee came to kno....

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....tricity respectively). The Assessing Officer determined the total income of the assessee at Rs. 31,40,230/- by alleging that the expenses were not incurred by the assessee in relation to its business operation. 4. Aggrieved by the above order, the assessee preferred an appeal before the ld. CIT(A) challenging the disallowances made by the Assessing Officer. However, the ld. CIT(A) upheld the order of the Assessing Officer and dismissed the appeal without adequately considering the submissions and supporting documents provided by the assessee. 5. Dissatisfied with the above order, the assessee is in appeal before this Tribunal raising multiple grounds. However, the main contention of the ld. AR is that the Assessing Officer went beyond....

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....bmitting relevant documents. We note that the assessee submitted sufficient documents in relation to the expenses and no discrepancies were identified during the assessment proceedings on the part of the Assessing Officer. Even, the books of account of the assessee were not rejected by the Assessing Officer. We also find that no reasons had been recorded for expanding the scope of limited scrutiny, no approval was taken from the PCIT for conversion of the limited scrutiny case to a complete scrutiny case. We also note that the Assessing Officer without converting the case into complete security and without obtaining necessary approval cannot disallow the expenses beyond the scope of limited security which is lacking in the present case whil....