TaxTMI 
TaxTMI 
2025 (8) TMI 1856
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....) by AO (hereinafter referred to as 'ld. AO'). 2. The assessee has raised the original grounds of appeal as under:- "1. That on facts, and in the circumstances of the case and in law, the CIT(A) erred in confirming addition of Rs. 2,79,200/- as undisclosed income u/s. 69A being cash deposited in the bank account maintained with ICICI Bank without considering the fact that the assessee is a salaried class employee having no other source of income and cash deposited in the bank account was from past withdrawals including savings, thus the assessee prays that addition of Rs. 2,79,200/- deserves to be deleted in full. 2. That on facts, and in the circumstances of the case and in law, the CIT(A) erred in confirming addition ....
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....rty was purchased as per the market rate prevailing in the locality where the property is situated, thus the assessee prays that the matter of valuation of the property may kindly be referred to the DVO. 5.That the assessee is praying for TDS credit of Rs. 4,000/- duly reflected in Form 26AS not allowed by the AO. 6. The above grounds of appeal are without prejudice to each other. The appellant may be allowed to add/amend/withdraw any grounds of appeal at the time of hearing or at any time before hearing with due permission of the Hon'ble Tribunal." 3. The assessee has raised the following additional grounds of appeal :- 1. That on facts, and in the circumstances of the case and in law, the National Faceles....
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....ded provisions by recording incorrect reasons to believe may kindly be held as bad in law, accordingly it is requested to declare the reassessment order dated 26/03/2022 passed u/s.147 r.w.s 144 r.w.s 144B as unsustainable in the eyes of law. (4). That on facts, and in the circumstances of the case and in law, the both the lower erred in making/confirming the addition of Rs. 15,90,000/- u/s.56(2) (vii) clause (b) without considering the fact that provisions of the section u/s. 56(2)(vii) being deeming provision should be strictly construed, accordingly the addition of Rs. 15,90,000/- solely in the assessee ignoring the registered sale deed filed which reflects co-ownership, may kindly be deleted in full. (B). Additional le....
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....udication of the aforesaid additional grounds are already placed on record and they go to the root of the matter. Hence we deem it fit to admit those additional grounds and take up the same first for adjudication. 5. I have heard the rival submissions and perused the materials available on record. I find that the Learned DR had placed the comments received from the Learned AO vide letter dated 4.8.2025 with regard to the additional grounds raised by the assessee. The following list of dates and gists would be relevant for adjudication of the additional ground no. 1 raised by the assessee:- a) Return of income for the Assessment Year 2017-18 was filed already by the assessee but the same was considered invalid due to non-validati....
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....ideration is as to whether the Learned FAO could assume jurisdiction to frame the re-assessment proceedings before the issuance of Notification No 18/2022 dated 29-3-2022 under section 151A of the Act or not? In this regard, it would be relevant to reproduce the provisions of section 151A of the Act which reads as under:- "151A. Faceless assessment of income escaping assessment. (1) The Central Government may make a scheme, by notification in the Official Gazette, for the purposes of assessment, reassessment or re-computation under section 147 or issuance of notice under section 148 10 [or conducting of enquiries or issuance of show-cause notice or passing of order under section 148A] or sanction for issue of such notice u....