TaxTMI 
TaxTMI 
2025 (12) TMI 659
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....d Commissioner of Income Tax (Appeals) [Ld. CIT(A) is bad both in the eyes of law and on facts and thus, liable to be quashed. 2. On the facts and circumstances of the case, the Ld. CIT(A) has erred both on facts and in law passing the order without giving assessee an opportunity of being heard, in violation of the principle of natural justice. 3. On the facts and circumstances of the case and in law, the Ld. CIT(A) has erred both on facts and in law in confirming the additions in the order passed u/s. 153C of the Act, without any incriminating material having been found during the course of search. 4. (i) On the facts and circumstances of the case, the Ld. CIT(A) has erred both on facts and in law in confirming t....
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....s been granted in a mechanical manner and as such the assessment order so passed is illegal and void-ab-initio 8. On the facts and circumstances of the case, the Ed. CIT(A) has erred in confirming the assessment of income at Rs. 35,69,750/- as against the returned income of Rs. 4,79,750/-. 9. (i) On the facts and circumstances of the case, the Ld. CIT(A) 8 has erred in confirming the addition of Rs. 25,00,000/- u/s. 69A of the Act on account of payment made to M/s Diwakar Commercial Private Limited. (ii) That the aforesaid addition has been made by the AO arbitrarily rejecting the explanation and evidences brought on record by the appellant. 10. (i) On the facts and circumstances of the case, the Ld. CIT(A) has er....
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....ully craves for leave to add, amend, alter, omit or substitute any of the grounds of appeal at 11 any time before or at the time of hearing of the appeal. The above grounds of appeal are mutually exclusive and without prejudice to each other. 3. The assessee also filed application for admission of the following additional ground under Rule 11 of the ITAT Rules :- "14. (i) On the facts and circumstances of the case, the Ld. CIT(A) has erred both on facts and in law in confirming the issuance of notice u/s. 153C of the Act as same is not covered within the ambit of 'relevant assessment year' as defined in Explanation 1 to 4th Proviso to Section 153A(1) of the Act and is thus without jurisdiction, barred by limitation, bad in law, ....
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....t to the search in Alankit Group certain documents were received by the AO of the Assessee company from the AO of the searched person on 24.06.2022 and subsequently a notice u/s. 153C was issued to the assessee by the AO on 26.07.2022. 9. The learned Counsel submitted that following the judgment of Hon'ble High Court of the Delhi in the case of PCIT Vs. Ojjus Medicare Private Limited, the date of commencement for computation of 6 years block period u/s. 153C shall be reckoned from the date of receipt of the books of the accounts documents or assets seized by the jurisdictional AO of the non searched person i.e. the assessee. Therefore, it is sated that in the case of the Assessee the search date will have to be considered as on 24.06.202....