2025 (4) TMI 1783

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....er referred to as "CIT(A)"] for the Assessment Year (AY) 2018-19. The first appeal - i.e. ITA No.2080/Ahd/2024 challenges the ex-parte order dated 08.10.2024 passed by the Ld. CIT(A) dismissing the assessee's appeal against the assessment order dated 24.03.2023 passed under section 147 r.w.s. 144 of the Act passed by the Assessing Officer [hereinafter referred to as "AO"] The second appeal - i.e. ITA No.2081/Ahd/2024 challenges the order of the CIT(A) dated 08.10.2024 passed under section 250 of the Act upholding the penalty levied under section 270A of the Act by the AO vide his order dated 21.09.2023. Facts of the Case: 2. The assessee is a closely held company engaged in the business of execution of Government contracts. It maintai....

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....,47,21,400/- is wholly illegal, unlawful and against the principles of natural justice. 1.2 The Ld. CIT(A) has grievously erred in law and or on facts in dismissing the appeal on the ground of limitation holding that there was no sufficient cause for delay in filing the appeal before NFAC and thereby confirming the aggregate additions of Rs. 3,47,21,400/- 1.3 The Ld. CIT(A) has grievously erred in law and or on facts in confirming exparte assessment u/s 144 as well as failed to appreciate that there was sufficient cause for alleged non-compliance to the notices of hearing issued so that the assessment is liable to be struck down. 2.1 The Ld. CIT(A) has grievously erred in law and or on facts in confirming the aggr....

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....ed the date of mail on 22.09.2023 as the date of service. 2.1 The Ld. CIT(A) has grievously erred in law and or on facts in confirming the penalty of Rs. 56,38,318/- imposed u/s 270A in respect of the aggregate additions of Rs. 3,47,21,400/- made by AO. 2.2 That in the facts and circumstances of the case as well as in law, the Ld. AO has grievously erred in confirming the penalty of Rs.56,38,318/- imposed u/s 270A in respect of the aggregate additions of Rs. 3,47,21,400/- made by AO. 3.1 Without prejudice to above and in the alternative the impugned penalty imposed by AO is highly excessive and calls for substantial reduction and relief on the ground of telescoping additions. It is therefore prayed that the delay ....