2025 (8) TMI 451

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....sed against the assessment order u/s 143(3) of the Act, dated 21.04.2021. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: "1. For that the order dated April 21, 2021 is bad in law and in gross violation of the principles of natural justice and has been passed without giving the appellant the opportunity of being heard. 2. For that on the facts and circumstances of the case, the Ld. AO erred in adding back 14,32,268/- u/s 14A of the Act and as well as exempted dividend income of Rs. 3,38,245/- also added in computed total income, when all related information, documents and evidences, calculations were duly filed. 3. The Order of AO to make an addition of Rs. 14,32,268/- ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....one through the assessment order as well as the submission of the assessee. On examining the same, it is observed that the assessee had invested huge sums in variety of shares in various companies there would be a certain element of expenses incurred towards managing of those shares and also a time cost involved for utilizing the funds invested to realize maximum profit. It could be also seen that there are expenses such as printing and stationery, electricity, rent, bank charges, sundry expenses etc. would be relatable to the earning of income from investment. It cannot be denied that the assessee personally involved in the carried out on those transactions. Hence, these grounds of appeal raised by the assessee is dismissed." 4. None ap....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....p;          2 = 1,60,88,846 + 12,71,38,034 1% of Rs. 14,32,26,880 = Rs. 14,32,268/-" 6. The Ld. CIT(A) has discussed the issue in para 5.2.1, to which our attention was drawn by the Ld. DR, who also submitted that the order of the Ld. CIT(A) being a reasoned order and there being no justification for the relief claimed by the assessee, the same ought to be upheld. 7. We have considered the submission made. The assessee contends that the order had been passed without giving a reasonable opportunity of being heard to the assessee. The Ld. AO issued show cause notice on 13.04.2021 to which the assessee replied on 15.04.2021 and after considering the reply and provisi....