2025 (9) TMI 1647

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.... interest claimed. 2. The learned CIT(A) has erred in deciding the appeal without giving any opportunity as per CBDT Notification No. 139/2021/F. No. 370142/66/2021-TPL notified the Faceless Appeal Scheme, 2021 (hereinafter referred to as 'new scheme') applicable w.e.f. 28 December 2021 which is in supersession of the old scheme, Which is against natural justice as no notice was given after Dec 2020. When appeal decided in June 2024. 3. The learned CIT(A) has erred in law and in the facts confirming the issue of notice u/s 148 and recording of reason, when the AO was having no jurisdiction over the assessee. 4. The learned CIT(A) has erred in law in the facts confirming the issue of notice u/s 148 when rea....

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....has escaped assessment and notice under section 148 dt. 29/03/2019 was issued by ITO, Ward Nabha. Thereafter, case of the assessee was transferred to DCIT, Mandi Gobindgarh and in response to the initial notice dt. 29/03/2019, the assessee filed its return of income on 21/10/2019 thereafter notice under section 143(2) and 142(1) were issued calling for necessary information/ documentation from the assessee. During the course of assessment proceeding, the AO noted from the computation of income furnished by the assessee that he has claimed expenditure of Rs. 10,12,400/- as interest paid under the head "income from other sources" and vide notice dt. 28/11/2019 necessary information, details alongwith documentary evidence like interest certifi....

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....duce the certificate / confirmation from the person to whom the assessee has paid the interest. It was submitted that the AO did not provide sufficient opportunity to the assessee and has hurriedly decided the matter by providing a very short period to respond and being an old matter, the assessee could not respond with the necessary certificate / confirmation from the person to whom he has paid the interest. It was submitted that the assessee has since obtained the confirmation and which has been placed as part of the assessee's paper book wherein Mr. Vivek Jindal has confirmed that the assessee has paid an amount of Rs. 10,12,400/- to him for the financial year relevant to impugned assessment year. It was further submitted that the simila....