2024 (5) TMI 1643

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....einafter referred to as "the Act") dated 29.12.2017 by the Assessing Officer, ACIT, Central Circle-13, New Delhi (hereinafter referred to as "ld. AO"). 2. None appeared on behalf of the assessee despite issuance of notice to the assessee. Infact on earlier occasions, there was representation from the side of the assessee and on one occasion, the ld. AR was also directed to certify the paper book in this appeal. Even after taking note of the subsequent date of hearings, there was no representation from the side of the assessee. Hence the Bench felt it appropriate to proceed with the disposal of this appeal on hearing the ld. DR and based on materials available on record. 3. The assessee has raised the following grounds of appeal before....

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....y the AO and confirmed by the Ld. CIT(A) is unjust, illegal, arbitrary and excessive. 6. That the above grounds of appeal will be argued in detail at the time of hearing and the appellant crave leave to submit additional grounds of appeal, if any, and/or alter, verify, modify or rectify any grounds of appeal at or before the time of hearing." 4. We have heard the ld. DR and perused the materials available on record. Since the paper book filed by the assessee is not certified by the assessee or by its authorized representative, the same is not taken into cognizance and is hereby ignored. The return of income for the Asst Year 2015-16 was electronically filed by the assessee company on 24.09.2015 declaring total income of Rs 7,983....

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....er criteria for scrutiny selection. This ground is not tenable. This ground is dismissed. It must be understood that in matter involving a corporate entity having engaged in complex transactions, it is but required to raise and seek replies to some queries in order to reach a reasonable and lawful conclusion. Similar issue has been decided in the cases pertaining to the group. This ground is therefore, dismissed. B. Grounds 2 & 3- a. The AO had concluded while framing assessment for AY 2014-15 that the assessee was not doing any actual purchase or sale and are the mere name lender. The AO sought to follow the same in this period also. The appellant has just stated that - "All the purchases and sale were genuine. I....