2026 (2) TMI 1308

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....Appellant : Shri M.S. Chhajed, AR For the Respondent : Shri Sher Singh, CIT (DR) & Shri Pradeep Sharma, Sr. DR ORDER PER DR. B.R.R. KUMAR, VICE-PRESIDENT:- These three appeals have been preferred by the assessee against separate orders passed by the lower authorities for Assessment Year 2013-14. The first appeal is directed against the order dated 20.01.2023 passed by the Income-tax Of....

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....ted order. ITA No. 114/Ahd/2023 3. The assessee has raised following grounds of appeal:- "1. The order passed by the Ld. CIT(A) is against law, equity & Justice. 2. The Ld. AO has erred in law and facts in making addition of Rs. 1,79,90,500/- as unexplained investment u/s 69 of the Act." 3.1 The assessee has raised following additional grounds of appeal:- "1. Th....

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.... limitation period reported in [2022] 134 taxmann.com 307 (SC)/[2022]/441 ITR 722(SC)/[2022] for limitation arising during the period of 15.03.2020 to 28.02.2022 29.05.2022 Date of Filing of return under section 148 of the Act 10.02.2022 Time Limit for issuance of notice U/s 143(2) of the Act 30.09.2022 Date of issuance of Notice U/s 143(2) of the Act Not issued Due date of....

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....used the record. It is an admitted position that the assessee filed return of income on 10.02.2022 in response to notice issued u/s 148 of the Act. It is further undisputed fact that no notice u/s 143(2) of the Act was issued within the prescribed time limit or thereafter. The contention of the Revenue is that since the assessment was ultimately framed u/s 144 of the Act, the requirement of issuan....