TaxTMI 
TaxTMI 
2026 (2) TMI 257
X X X X Extracts X X X X
X X X X Extracts X X X X
....IT (Appeals), NFAC, Delhi has erred in confirming the ex parte order passed under section 147 r.w.s. 144 read with section 144B of the Act, as the reassessment proceedings under Section 148 of the Act has been initiated by the JAO vide notice dtd. 05-04-2022 after introduction of e- Assessment/Faceless Income Escaping Assessment Scheme, 2022 under Section 151A of the Act and hence, the notice issued by the JAO is without jurisdiction and illegal and also in violation of Notification No: 18/2022 dtd. 29-03-2022, requires to be quashed. 2. On the facts and in the circumstances of the case as well as in law, the CIT (Appeals), NFAC, Delhi has erred in confirming the ex parte order passed under section 147 r.w.s. 144 read with section ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....- u/s 270A of the Act, which is without jurisdiction, bad in law, illegal, invalid, arbitrary and hence liable to be quashed. 3. Your appellant further reserves his rights to add, alter, amend or modify any of the aforesaid grounds before or at the time of hearing of an appeal. Total tax effect (penalty) 2,42,615/-" ITA No. 2256/Ahd/2025 A.Y. 2018-19 "1. On the facts and in the circumstances of the case as well as in law, the CIT (Appeals), NFAC, Delhi has erred in confirming the ex parte order passed under section 271AAC(1) of the Act, which is in pure violation of the principles of natural justice, without jurisdiction, bad in law, illegal, invalid, arbitrary, void ab initio and hence liable to be quashed. ....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... well as in law, the CIT (Appeals), NFAC, Delhi has erred in confirming the ex parte order passed under section 147 r.w.s. 144 read with section 144B of the Act, as the reassessment proceedings under Section 148 of the Act has been initiated by the JAO vide notice dtd. 13-03-2023 after introduction of e- Assessment/Faceless Income Escaping Assessment Scheme, 2022 under Section 151A of the Act and hence, the notice issued by the JAO is without jurisdiction and illegal and also in violation of Notification No: 18/2022 dtd. 29-03-2022, requires to be quashed. 2. On the facts and in the circumstances of the case as well as in law, the CIT (Appeals), NFAC, Delhi has erred in confirming the ex parte order passed under section 147 r.w.s. ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....f Rs. 1,90,773/- u/s 270A of the Act, which is without jurisdiction, bad in law, illegal, invalid, arbitrary and hence liable to be quashed. 3. Your appellant further reserves his rights to add, alter, amend or modify any of the aforesaid grounds before or at the time of hearing of an appeal. Total tax effect (penalty) 1,90,773/-" ITA No. 2260/Ahd/2025 A.Y. 2019-20 "1. On the facts and in the circumstances of the case as well as in law, the CIT (Appeals), NFAC, Delhi has erred in confirming the ex parte order passed under section 271AAC(1) of the Act, which is in pure violation of the principles of natural justice, without jurisdiction, bad in law, illegal, invalid, arbitrary, void ab initio and hence liable to....
X X X X Extracts X X X X
X X X X Extracts X X X X
....n firstly. The assessee is engaged in the business of purchase and sale of Dairy Cattles and did not file the return of income during the year under consideration. The assessee is having brokerage income for supply of Dairy Cattles and is registered Dairy Cattle broker of Vadodara JillaSahakariDudhUtpadakSangh Ltd., Vadodara. The Assessing Officer received information that the assessee carried out following transactions during the period relevant to A.Y. 2018-19: Sr. No. Description of transaction Transaction period Amount (Rs.) 1 Cash deposit in current a/c F.Y. 2017-18 2,78,000 2 Cash withdrawals in current a/c F.Y. 2017-18 2,19,39,700 3 Time Deposit F.Y. 2017-18 2,11,000 4 Sale of Mot....
X X X X Extracts X X X X
X X X X Extracts X X X X
....itting therein that despite giving several opportunity, the assessee did not respond the notices before the Assessing Officer as well as before the CIT(A). 7. Heard both the sides and perused all the relevant material available on record. It is pertinent to note that the assessee is not well versed with the law and because of which could not represent his case properly before both the Revenue authorities. But the assessee also did not file the requisite details before the authorities, therefore, the assessee is directed to pay cost of Rs. 2,000/- in appeal to the "Prime Minister's Relief Fund" within the period of 2 weeks from the date of receipt of this order. It will be appropriate to remand back this matter to the file of the Assessin....