required under s. 158BC of the Act is vague and bad in law, all the consequential actions including the assessment for block period are illegal ... support of the submissions that the notice was illegal and bad in law, the assessee's counsel has placed reliance on the decisions
Delhi & M/s. Superior
Buildwell Private Limited, Delhi.
bad in law. He has submitted that in proceedings under
section ... assessment order is bad in law. Learned
Counsel for the Assessee relied upon the Order of ITAT, Delhi
Bench in the case
2019 M/s. Charbuja
Marmo (India) Pvt. Ltd., Delhi.
and bad in law and liable to be quashed. He has submitted
that reasons recorded ... approval granted by Addl. CIT and Pr. CIT
are invalid and bad in law. Learned Counsel for the
Assessee, therefore, submitted that proceedings under
this case is wrong, bad in law
and the penalty so levied ought to have been deleted by the Learned
CIT(A).
2.That ... mentioning the charges on which penalty
was actually levied, was bad in law and had has led to vitiation of the
entire penalty proceedings, therefore
suspicion and therefore, the action u/s.132 [1] is bad in law
[224 ITR 19 (SC)] and consequent assessment U/ S.153A ... persons
said to have been specified in the warrant is bad in law to
initiate search in the individual cases of the several persons
whose
2010
Page 3 of 56
3.1 The reference to TPO is bad in law as the mandatory
conditions have not been satisfied or complied with ... matter was referred to
the TPO.
3.2 The order is further bad in law as the appellant was denied
of opportunity of being heard before
irrelevant considerations, against natural justice, contrary to
facts, arbitrary, erroneous and bad in law.
2. Disallowance under "Peripheral Development Expenses ... based on irrelevant considerations, contrary to
facts, arbitrary, erroneous and bad in law.
b That the aforesaid expenditure of Rs.56,27,609/- having been
justified in sustaining the assessment order, which
is bad-in-law, void ab initio, barred by limitation, illegal, contrary to the
facts and circumstances ... liable to be annulled.
2. That the additions are illegal and bad in law as they are not based on
any incriminating material found during
office of the Registrar of Companies and in any case bad in law.
(vii) That the learned AO while relying on the statement of Shri ... various additions made (aggregating to Rs. 1,68,04,856) are bad in law having been made in violation of the statutory provisions of Section
invalid notice under Section 158BC of the Act were illegal and bad in law/void ab initio.
6. The learned Departmental Representative, on the other ... which a notice under Section 148 can be held to be bad in law are sufficient to hold a notice under Section 158BC as bad
