2025 (10) TMI 526

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....ly proceeded ex-parte. 3. Delay 172 days in filing of the instant appeal is condoned in light of the assessee's contention petition explaining the same to be attributed to various circumstances beyond it's control. 4. The assessee pleads the following substantive grounds in the instant appeal: "1. Because the Ld. C.I.T. Appeal, New Delhi has not considered the facts and circumstances of the case and confirm the addition of Income of Rs. 3,379,074/- u/s 68 of the Income tax Act, is illegal and bad in law. 2. Assessee has maintained books of account in the ordinary and normal course of business, audited u/s 44 AB of the Income Tax Act 1961 whether in facts the assessment proceeding has been completed ex-parte u/s 144 o....

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.... firm and continuously asses Status of partnership firm Pan bearing no AAGFA5916R and if Ld AO computed the net profit of 8% then the also remuneration to partner and interest paid on capital treat as business expenditure becomes liable to allow deduction and the provision of Income tax act and such firm not liable to assessed as AOP .Judges shall not withdrawal from judging. 7. Because of the Earlier Assessee regularly assessed with the department. During each and every year, assessment proceeding has been completing under 142(3) of the Act and the net profit is always 52.50% to 6.21% till now. Therefore, how the excessive profit could be computed when this is the same firm with same promoters & same work. 8. Because of t....

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.... remuneration of the partners and interest of the capital which is against the principle of natural justice. 10. Because charging the Interest u/s 234A, 234B and 234C is illegal and bad in law. 11. The Addition is bad in law and harsh. 12. The Addition is not proper and unjust and thus not supported by law." 4. It next emerges with the able assistance coming from the Revenue side that the learned Assessing Officer had framed his section 144 assessment on 28.03.2013 inter alia making twin additions of GP estimation @ 8% on gross receipts of Rs. 5,91,96,282/-; resulting in addition of Rs. 22,18,017/- after rejecting books of account followed by disallowance of partners remuneration amounting to Rs. 11,61,052/-; r....