2024 (4) TMI 1423

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....icer u/s 144 r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred to as "the Act"), dated 31.03.2022. 2. The grounds of appeal raised by the assessee are as follows: "1. On the facts and circumstances of the case as well as law on the subject, the learned CIT (A) has erred in not admitting the appeal u/s 249(4) when no tax was payable as advance tax. 2. On the facts and circumstances of the case as well as law on the subject, the learned assessing officer has erred in reopening assessment u/s. 147 of the Act by issuing notice u/s. 148 of the IT Act 1961. 3. On the facts and circumstances of the case as well as law on the subject, the learned assessing officer has erred in making addition of Rs. 14,....

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....r, the Tribunal has inter alia observed as follows: "7. I have heard the rival arguments made by both the sides and perused the material available on record. Admittedly, the Assessing Officer during the assessment proceedings, wrongly made addition in the hands of assessee-firm, as the assessee-firm, was not in in existence, during the assessment year (AY).2017-18. The assessee was partnership firm engaged in the business of manufacturing of Chemicals. It was converted into a Private Limited Company namely Arochem Industries Private Limited, under part IX of the companies Act 2013 on date 12.03.2014. On receiving the notice u/s 148, the assessee filed a written submission before the assessing officer stating this fact and that sinc....