TaxTMI 
TaxTMI 
2026 (6) TMI 983
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....er passed by the Assessing Officer (for short, "AO") under section 147 r.w.s 144 r.w.s 144B of the Income Tax Act, 1961 (for short, "the Act"), dated 08/03/2024. The assessee society has assailed the impugned order of the CIT(A) on the following grounds of appeal: "1. On the facts and in the circumstances of the case, the order of the ld. CIT(A) is erroneous both on facts and in law and is passed in gross violation of principles of natural justice. The Id. CIT(A) failed to appreciate that the notices were not properly served on the appellant. 2. Without prejudice to the above, the Id. CIT(A) erred in sustaining the addition made by the AO of Rs. 33,09,635 as income from other sources. The authorities below failed to apprec....
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....as called upon by the AO to explain as to why the assessment in its case be not framed to the best of his judgment under section 144 of the Act. 3. During the course of the assessment proceedings, the assessee society furnished its reply to some of the notices issued under section 142(1) of the Act. 4. The AO, on perusal of the details furnished by the assessee society and those gathered from the bank under section 133(6) of the Act, observed that it had during the subject year made cash deposits of Rs. 1,16,10,663/-. As the assessee society had failed to come forth with any explanation regarding the source of the aforesaid investment aggregating to Rs. 1,77,99,986/-, the AO called upon it to explain as to why the same may not be trea....
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....5/-. 6. Aggrieved, the assessee society carried the matter in appeal before the CIT(A). As the assessee society, despite having been afforded sufficient opportunity, had failed to participate in the appellate proceedings, the CIT(A) finding no infirmity in the well-reasoned speaking order passed by the AO upheld the same and dismissed the appeal. 7. The assessee society, aggrieved with the order of the CIT(A) has carried the matter in appeal before us. 8. Shri AV Raghuram, Advocate, Learned Authorized Representative (for short, "Ld. AR") for the assessee society, at the threshold of hearing of the appeal, submitted that both the authorities below had grossly erred in law and facts of the case in making/sustaining the addition of Rs....
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....m that, the Ld. AR submitted that both the authorities below had also erred in not giving credit for tax deducted at source (TDS) of Rs. 1,00,547/- while computing the tax liability. 9. Per contra, Shri Vamshi Krishna, Learned Senior Departmental Representative (for short, "Ld. Sr-DR") relied upon the orders of the authorities below. 10. We have given thoughtful consideration to the contentions advanced by the Learned Authorized Representatives of both parties, perused the orders of the authorities below and the material available on record. 11. Admittedly, it is a matter of fact discernible from the record that the income of the assessee society as computed by the AO at Rs. 33,09,635/- had been subjected to tax as per the Maximum ....