2025 (10) TMI 430

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....DER PER RENU JAUHRI [A.M.] :- This appeal is filed by the assessee against the order of the Learned Commissioner of Income-tax (Appeals), Mumbai/National Faceless Appeal Centre, Delhi [hereinafter referred to as "CIT(A)"] dated 12.09.2023 passed u/s. 250 of the Income-tax Act, 1961 [hereinafter referred to as "Act"] for the Assessment Year [A.Y.] 2012-13. 2. The grounds of appeal are as f....

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..../s. 271(1)(c) of the Income tax Act, 1961 ignoring the fact that the quantum addition has been confirmed by the Ld. CIT(A) and thus the claim of bad debts of the assessee company is a clear case of furnishing inaccurate particulars of income" The Appellant craves leave to add, amend and/or vary the grounds of Appeal before or during the course of hearing." 3. Brief fact of the case are....

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....7.1 The submission of the appellant is considered and it is seen that this the first year of filing the ITR and bad debts has been claimed. It is seen that appellant has recorded the bad debts in books of account as well as in computation of income. However, AO has not agreed to it and disallowed these bad debts. As per various judicial pronouncements, disagreeing of AO can not be reason for levy ....

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....he assessee could not file the appeal against the assessment order in time as the company went into liquidation due to orders passed by the Hon'ble Bombay High Court on 10.02.2015 and 05.02.2016. Subsequently, appeal is stated to have been filed against the assessment order also. However, in the meanwhile, penalty u/s. 271(1)(c) has been imposed by ld. AO for furnishing inaccurate particulars of i....