2024 (8) TMI 1738

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....JCIT(DR) ORDER PER DR. DIPAK P. RIPOTE, AM: This appeal filed by the assessee is against the order of ld. Commissioner of Income Tax-(Appeal)-6/JCIT, Kolkata under section 250 of the Act, dated 04.04.2024 for the Assessment Year 2012-13. The assessee has raised the following grounds of appeal : "The CIT Appeals has erred in appreciating the fact that the AO during the course of a....

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....3). The CIT Appeals has erred in not appreciating the fact that no opportunity to cross examine the concerned party from whom the alleged purchases were made was provided where the assessee has completely denied to have made such cash purchases during the year. The CIT Appeals has erred in not appreciating the fact that during the entire FY 2011-12 the total sales were for Rs. 58....

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....in assessment proceedings. The CIT Appeals erred in law and facts ignoring the legal position considered by various judicial authorities that if no copy of material documents, statements containing information of cash purchases as referred in the assessment order and ultimately relied by the AO to support the addition were not confronted to the appellant during assessment and appellate pr....

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.... u/s.148 of the Act was issued. However, till date, no such information has been provided. Ld.AR submitted that the AO was not having any information and notice u/sec.148 is bad in law. Ld.AR also submitted that AO has violated principle of natural justice, hence assessment order is bad in law. Ld.AR further submitted that during the year, total sale of the assessee was only Rs. 5,82,217/- and tot....