TaxTMI 
TaxTMI 
2025 (12) TMI 597
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....8.10.2024 for Assessment year 2017-18. 2. The assessee has raised following grounds of appeal: 1. That having regard to the facts and circumstances of the case, assumption of jurisdiction in initiating the proceedings u/s. 147 and passing the impugned order u/s. 147/144B and that too without complying with mandatory conditions u/s. 147 to 151A as envisaged under the Income Tax Act, 1961, is bad in law and against the facts and circumstances of the case. 2. That in any case and in any view of the matter, assumption of jurisdiction u/s. 147 and passing the impugned order u/s. 147/144B, is illegal, bad in law and against the facts and circumstances of the case and the same is not sustainable on legal and factual grounds. ....
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....s of appeal No. 1 & 2 are not pressed thus are dismissed. 4. The Grounds of appeal 2 to 5 are with respect to the addition of Rs. 90.00 lacs made u/s. 68 r.w.s. 115BBE of the Act wherein the assessee also challenged the action of the AO and CIT(A) in confirming the additions by violating the principle of natural justice. 5. Before us, ld.AR of the assessee submits that before the AO, assessee had filed the confirmations of the loans taken and also filed their ITR's wherein the interest paid by the assessee was duly offered for tax by the lender companies. Copies of the bank statements of both the lender companies were also filed. However, the AO in absence of their financial statements held the credits as unexplained and made the addi....
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.... prayer, ld. AR stated the reasons for non-filing these evidences before the lower authorities and further placed reliance on various judicial pronouncements. The petition made reads as under: 1. It is respectfully submitted that the non-production of the aforesaid evidences at item no. (i) to (v) before the Ld. CIT(A) was on account of sufficient and bonafide cause. The appellant's authorized representative (CA) had specifically sought adjournment on 19.09.2024 (PB 47-48) on the ground that the appellant was in the process of collecting relevant evidences and information, and further, that the representative was pre-occupied with statutory September-end audit/reporting obligations. However, without granting adequate opportunit....
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....(ITAT, Agra) * Electro (Jaipur) (P) Ltd. vs Inspecting Assisting Commissioner, 26 ITD 236. (ITAT, Delhi) * Rajmoti Industries vs ITO 52 ITD 286 (ITAT, Ahmadabad) * Mahavir Prasad Gupta vs JCIT 101 TTJ 1078. (ITAT, Delhi) * CIT vs Mukta Metal Works, 336 ITR 555 (P&H) It is further submitted that Your Honours have ample powers in this regard under the law as explained by Jurisdictional Delhi Court in the case of CIT vs. Text Hundred India Pvt. Ltd., (2013) 351 ITR 0057, dated 14.1.2011, we humbly submit that in order to make substantial justice and to prevent failure of justice, the aforesaid evidence may please be admitted for consideration and my appeal may please be decided accordingly. 5.2 I....