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Income Tax Appellate Tribunal, DELHI ‘SMC’ BENCH, NEW DELHI
Before: SHRI H.S. SIDHU
This appeal is filed by the assessee against the order of the Ld. Commissioner of Income Tax [Appeals-14], New Delhi dated 06.11.2018 pertaining to assessment year 2010-11 on the following grounds:-
1. The order passed by the AO and Ld. CIT(A) is bad in law and against the facts of the case.
2. That the AO erred in invoking provisions of section 68 of the Act.
3. That the Ld. CIT(A) erred in sustaining the addition without considering the fact that the AO erred in making the assessment proceedings without issuing notice u/s. 143(2) of the Income Tax Act, 1961 which makes the whole assessment proceedings null and void.
4. That the Ld. CIT(A) erred in sustaining the addition made by the AO amounting to Rs. 16,22,500/- on account of unexplained cash credit u/s. 68 of the Income Tax Act, 1961.
5. That the Ld. CIT(A) and AO erred in passing the order without providing an opportunity of being heard.
That the order of the Ld. AO is based in assumption and presumption which is against the law.
That the AO erred in initiating penalty u/s. 271(1)©. 8. That the AO and Ld. CIT(A) also erred in not following various judgments of jurisdictional High Court and ITAT. 9. That the appellant craves leave to add, alter, modify or delete any of the ground of appeal
2. Prayer On the facts and in the circumstances of the case and in view of judicial precedents, it is humbly prayed that:-
1. Order passed u/s. 144/147 be quashed and set aside;
2. Addition of Rs. 16,22,500/- be deleted and 3. Penalty proceedings u/s. 271(1)© of the Act be dropped.