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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
SHRI VIKRAM SINGH YADAV, A.M, SHRI ANIKESH BANERJEE, J.M
Ador Welding Limited – Appellant
Versus
Deputy Commissioner of Income Tax, Circle-2(1)(1) – Respondent
| Table of Content |
|---|
| 1. appellant's right to fair assessment processes. (Para 1 , 2 , 4 , 5 , 22) |
| 2. natural justice violations must be addressed. (Para 3 , 9 , 23) |
| 3. challenges on shifting allegations in assessment. (Para 6 , 10 , 12 , 21) |
| 4. completeness of evidence is crucial for conclusions. (Para 19 , 20) |
| 5. remand for further examination and verification. (Para 24 , 26) |
ORDER
PER VIKRAM SINGH YADAV, A.M :
This is an appeal filed by the assessee against the order of the Learned Commissioner of Income Tax (Appeals)-National Faceless Appeal Centre (NFAC), Delhi [„Ld. CIT(A)‟], dated 17-12-2024, pertaining to Assessment Year (AY) 2021-22.
2. At the outset, it is noted that there is a delay of 84 days in filing the appeal as pointed out by the Registry. After hearing both the parties and perusing the facts placed on record, we find that there was reasonable cause for the delay in filing the present appeal and hence, the delay is hereby condoned and appeal is admitted for adjudication.
3. Briefly the facts of the case are that the assessment in this case was completed u/s. 143(3) r.w.s. 144B of the Income Tax Act, 1961 („the Act‟) vide order dt. 13-12-2022, wherein the AO has brought to tax u
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