2024 (11) TMI 1502

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....ised following grounds of appeal : "1. The amount Rs. 14,47,700/- is taxed at maximum marginal rate. Considering the facts and circumstances of the case and in law prevailing on the subject the reassessment proceeding is not in accordance with the law and the provisions of the Income Tax Act, 1901. The assessee submits that the reassessment proceedings be held to he bad in law and struck down. 2. The reassessment proceedings u/s. 148 r.w.s. 144 of the Income tax Act in any view of change of opinion on the same facts and circumstances which were already in A. O's knowledge even during the original assessment proceedings. 3. The Ld. CIT while upholding addition and the Ld. AO while making assessment u/s. 143(3) rw.s. 147 having ma....

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....as relied upon is bad in law and hence passed assessment order to be quashed. 8. Assessed u/s. 144 rws 147 of the I.T. Act, 1961. Tax on the above income is calculated as per ITNS 150 forming part of this order. Credit for prepaid taxes is given after due verification. Interest u/s 234A, 2348, 2340 & 234D of the 1.T. Act, 1961 as applicable is charged. D.N./Challan is accordingly issued. Notice u/s 274 r.w.s 271(1)(c) of the Income Tax Act, 1961 is issued. 9. The appellant craves leave to add to alter, amend, modify and/or delete any or all of the above said grounds of appeal. The appellant reserve its right to file further submission in the appeal." 3. It may be stated here that there is delay in filing of appeal by the assessee. I....

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....fter making an addition of Rs.1,33,00,000- as undisclosed income. Appeal was filed against the said order dated 28/12/2018 passed by the AO u/s. 144 read with Section 147 of the Act. However, even in the appeal proceedings, assessee has not furnished any explanation in this regard. There is a finding of the Investigation Wing of the Department that Mr. Chandrakant Patel was indulging in providing accommodation entries and that he had provided such an accommodation entry to the appellant. The appellant's non-cooperation during assessment proceedings as well as the appellate proceedings only strengthens the above finding. Therefore, considering the overall facts and circumstances of the case, the action of the AO in taxing the amount of Rs. 1....