2025 (11) TMI 1131

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....h Shri Rushin Patel, ARs For the Revenue : Shri Hargovind Singh, Sr.DR ORDER PER NARENDRA PRASAD SINHA, AM: These two appeal are filed by the assessee against the separate orders passed by the Additional/Joint Commissioner of Income Tax (Appeals-1) Chandigarh, (in short "the CIT(A)") both dated 26.11.2024 for the Assessment Years 2012-13 & 2014-15 respectively. The facts involved in th....

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....47 of the Act, after recording proper reason and a notice u/s.148 of the Act was issued on 18.11.2019, in response to which the assessee had filed return of income declaring income of Rs. 4,73,960/-. In the course of assessment, the assessee had denied payment of any on-money towards acquisition of the property. However, the AO was not convinced with the explanation of the assessee as the bank acc....

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....the consequential reassessment order passed u/s.143(3) r.w.s. 147 are bad in law. 3. The Id. CIT(A) has erred in law and on facts of the case, in sustaining addition of Rs. 4,00,000/- u/s.68 on account of alleged on-money payment. 4. The appellant craves leave to add, amend or alter the grounds of appeal at the time of hearing, if need arise. 5. Shri M J Shah, Ld. AR appearing....

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....is found that the email address mentioned in Form No. 35 was [email protected] and the assessee had given his option that no notice/communication may be sent on the email. Under the circumstances, the disposal of the appeal by the Ld. CIT(A) by sending notice on the email and without sending any physical notice to the assessee, cannot be held as correct. When the Department had given an option ....