Loading judgment…
No AI summary yet for this case.
Income Tax Appellate Tribunal, “SMC” BENCH, AHMEDABAD
Before: DR. B.R.R. KUMAR, VICE-
O R D E R 1. Delay condoned.
This appeal has been filed by the Assessee against the order passed by the Ld. ADDL/JCIT(A)-1, Jaipur (hereinafter referred to as "CIT(A)" for short), dated 20.03.2024 passed under Section 250 of the Income-tax Act, 1961 [hereinafter referred to as "the Act" for short], for Assessment Year (AY) 2011-12.
The Assessee has taken following grounds of appeal:- “1. The order passed by Ld. CIT (A) is against law, equity & justice.
2. Reopening of assessment and consequential all actions are void & illegal as no sanction as requisite U/S 151 of the Act has been accorded
3. Ld CIT (A) has erred in law and on facts in upholding validity of assessment order passed without issuing notice u/s 143(2) of the Act.
4. The Ld. CIT (A) upheld the validity of assessment order passed by the Ld. AO u/s 144 r.w.s 147 of the Act. Badrish Pravinbhai Soni Vs. ITO Asst. Year : 2011-12 - 2–
The Ld. CIT (A) has erred in law and on facts in upholding addition made by the Ld. AO u/s 68 of the Act in regard to alleged unaccounted investment.
The Ld. CIT (A) has erred in law and on facts in upholding the addition made by the Ld. A.O. of Rs. 11,65,000/-. 7. Ld. CIT (A) has erred in law and on facts upheld the addition made by the Ld. A.O. merely relying on dumb documents. 8. The appellant Craves liberty to add amends, alter or modify all or any grounds of appeal
before final appeal.”
4. In this case, the assessment order has been passed by the ITO, Ward 2(2)(1), Ahmedabad on 30.11.2018 u/s 144 r.w.s. 147 of the Act determining total income of Rs.13,11,800/- against the returned income of Rs.1,46,860/-, on account of cash paid for acquisition of property. The ld. CIT(A) has summarily dismissed the appeal of the assessee owing to delay of 4 months and non-filing of explanation before him. Having gone through the record and having heard the arguments of the parties, it is hereby directed that the assessee shall submit the reasons for delay in filing of the appeal along with the details of their arguments on merit which the ld. CIT(A) shall consider and pass an order de novo.