2025 (8) TMI 429

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....red both in law and on facts while sustaining the addition made by Ld. A.O u/s. 69A r.w.s 115BBE of the I.T. Act, 1961 for Rs. 5,97,074/- which requires to be deleted. 02. That the Ld. CIT(A) has not adjudicated the legal grounds No.1 to Grounds No.10 and therefore the order passed by Ld.CIT(A) is against the principal of natural Justice, which requires to be quashed. 03. That the assessee Ld. CIT(A) has erred in law while not issuing of Notice u/s.148 of the I.T. Act, 1961 and therefore assessment order passed by National Faceless Assessment Centre, Delhi making heavy addition u/s. 69A r.w.s. 115BBE of Rs. 5,97,074/- is bad in law, illegal and void. 04. That the Ld. CIT(A) has breach the basic principle of natura....

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...., 1961 and therefore the reassessment order passed, requires to be quashed. 10. That the assessee has filled his detailed reply on 21/12/2021, 18/02/2022 and 25/03/2022, however without considering the documentary evidences on record, A.O. has passed an order u/s 148 r.w.s. 144 on presumption and assumption is against the provision of law and against the principle of natural justice and as such it requires to be deleted. 11. That the amount received by the assessee on sale of shares and security which is credited in Bank accounts of the assessee and also the A.O. is known the source of such amount, however without appreciating the facts addition made of Rs. 5,97,074/- u/s.69A r.w.s. 115BBE of the Act is against the provisi....

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.... which contains reasons recorded by the Assessing Officer and the return of income filed by the assessee. Paragraph no.3 of the reasons recorded reads as under :- "3. Analysis of information collected/received: On verification of details received, it is noticed that the assessee has made huge transaction during the year under consideration, the assessee has carried out huge transactions of purchase and sale of shares (penny stock) Further, the assessee has not shown any capital gain/loss in this ITR nor shown any business earnings. The information articulates the fact that the assessee indeed made bogus transactions by trading in penny scrip Aricent Infra Ltd. in order to veil the amount from being taxed legitimately. Ther....