2026 (9) TMI 1316

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....peals)-3, Noida, [hereinafter referred to as 'ld. CIT(A)] arising out of assessment order dated 29.09.2022 passed under section 143(3) of the Income Tax Act, 1961 pertaining to Assessment Year 2020-21. The word 'Act' herein this order would mean Income Tax Act, 1961. The assessee has also filed Cross objection. 2. The Revenue has raised following grounds of appeal:- "1. Whether on the facts and circumstances of the case and in law, the ld. CIT(A) erred in deleting the liability (provision) of Rs. 49,34,74,2271- whereas the assessee had furnished the list of sundry creditors with closing balance of Rs. 21,22,79,304/- (out of Rs. 70,57,53,531/-) only during the course of assessment proceedings. 2. Whether on the facts and....

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.....2020. The ld. AO concluded assessment determining total income at Rs. 74,83,24,648/- after making additions u/s 41(1) and disallowing certain expenditure both aggregating to Rs. 53 Crores approximately. 6. It is the case of the ld. Counsel of the assessee that the impugned assessment order is passed in the name of Bharat Construction a non-existent entity on the date of impugned assessment order dated 29.09.2022. The ld. Counsel submitted that it was earlier operating as a partnership firm however with effect from 19.01.2020, the said partnership firm converted into private limited company. The ld. Counsel submitted that through his letter dated 27.09.2022, it had conveyed this fact unequivocally to the ld. AO in response to his show-ca....