2024 (12) TMI 1618

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....both the parties at length. Case file perused. 3. The assessee pleads the following substantive grounds in the instant appeal: "1. In view of the facts and circumstances of the case, the order dated 23/10/2023 passed by the National Faceless Appeal Centre, Delhi ("NFAC/CIT(A)") is erroneous in confirming the order passed by Asst. Director of Income Tax, Centralized Processing Centre ("CPC")/NFAC under Section 143(1) of the Income Tax Act, 1961 ("the Act") as the disallowance made therein is illegal, bad in law, without jurisdiction and void ab-initio. The disallowance made is erroneous, unjustified and illegal. 2. In view of the facts and in the circumstances of the case, the CIT(A) has erred in confirming addition/disa....

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....ide on this ground alone. 8. That in view of the facts and circumstances of the case and in law, AO or CPC has erred in charging interest under Section 234A, 234B and 234C of the Act. The charging of interest is illegal and excessive and has been wrongly worked out. It cannot be justified by any material on record. 9. That the CIT(A)/CPC has failed to consider the material placed and available on record and has failed to judicially interpret the same as the same do not justify the addition/ disallowance made." 4. Suffice to say, learned counsel has raised three substantive arguments inter alia that both the lower authorities have erred in law and on facts in disallowing the assessee's ESI/PF claim of Rs. 7,34,403/- in s....