2025 (11) TMI 1252

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....er of Income-tax (Appeals), dated 30/01/2025, which in turn arises out of an order passed by the Assessing Officer dated 17/09/2021, u/s 143(3) read with section 144B of the Income Tax Act, 1961. 2. Grounds of appeal raised by the assessee are as follows: "(1) Assessment Order passed u/s. 143(3) r.w.s. 144B of the 1. T. Act, 1961 is bad in law. (2) The Learned AO has erred in law as well as fact in disallowing the expense of Rs. 4,67,800/- on account of various misc. items considering the same as alleged capital expense incurred by the appellant during the year under consideration. The learned CIT(A) has erred in confirming the same and dismissing the appeal of appellant in limine." 3. When the matter was called for ....

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....ist furnished by the assessee. Vide notice u/s 142(1) of the Act, dated 17.08.2021, assessee was asked to explain the same along with supporting documents. The assessee failed to comply with notice. Thereafter one more opportunity was given to the assessee, vide show-cause notice dated 11.09.2021 to explain the above said purchase along with supporting documents and allowability of the expenses and compliance was fixed on 15.09.2021. The assessee had complied to the notice till date of finalization of the order. However, the assessing officer noticed that assessee has nothing to say/explain and has not furnished any details/documentary evidence and failed to explain the said purchases. Accordingly, an amount of Rs. 4,67,800/- was disallowed....