2026 (4) TMI 171

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....und raised in the memo of appeal. BECAUSE, even otherwise, an order appeal without effectively disposing of the grounds raised by the appellant is in infraction of section 250(6) of the Act and as such, order so made is otherwise too illegal, invalid and a vitiated order. WITHOUT PREJUDICE TO THE ABOVE BECAUSE, upon due consideration of facts and in the overall circumstances of the case 'appellant' denies its liability to be assessed in terms of Notice dated 30.03.2019 said to be issued under section 148 of the 'Act'. BECAUSE, No Notice under section 178 of the 'Act' was served upon the 'appellant' and ex-parte assessment was completed without serving any Notice under section 148 of the 'Act' render the Assessm....

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....BECAUSE, in any case and in any view of the matter impugned addition and impugned assessment order is bad in law, illegal, unjustified, contrary to facts and law based upon incorrect assumption of facts and further without allowing adequate opportunity of hearing in violation of principals of natural justice and therefore, the additions made deserved to be quashed. BECAUSE, the assessment order to the extent making addition is bad in law and against the fact of the case. BECAUSE, assessee denies its liability against Interest charged under section 234A based on incorrect assumption of facts and Interest under section 234B and 234C is incorrectly charged. The 'appellant' craves leave to add, alter or vary the groun....

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....which is the return of the income filed by the assessee for the year under consideration and the same is placed on record. Further, he brought to our notice page 7 of the paper book wherein assessee has filed the return of income on 31.07.2013 and he brought to our notice the computation as per stamp duty under section 50C of the Act i.e. 36 lakhs and duly declared the relevant capital gain which is placed at page 8 of the paper book. In this regard, further he brought to our notice page 76 and 77 of the paper book, which is the form for recording reasons for reopening and obtaining approval under section 151 of the Act, in the above cited notices, at Column No 8, wherein it was shown as the assessee has voluntarily not filed return of inco....