Grounds of appeal order under 147 of the Income tax Act 1961 of Smt.

N Sampurna
W/o. N.Sambasiva Rao Age 65 resident of D.No 24-21-4, Durgapuram, Ashramam
Veedhi Vijayawada .

Facts of the case

I submit that , aggrieved by the assessment order dated 28/11/2018 passed by the
assessing authority ward 3(1) of Vijayawada in passing the impugned Assessment
order without considering the plea raised by the appellant vide our letters dated
21/05/2018, 13/11/2018 and 26/11/2018 in which the appellant stated that notice
received on 10.05.2018 and issued under section 148 of the Income tax act 1961,
and read with section 149 of the Income tax Act, 1961 is time barred and not valid
hence proceedings to be stalled as illegal, arbitrary, unjust, improper contrary to
the provisions of the Act. and consequently to set aside the impugned order dated
28.11.2018 and grant such other relief and reliefs as are deemed fit and proper
under the circumstances of the case.

Grounds of Appeal:

1. The learned assessing officer ( for short – the AO) erred by erroneously
assuming jurisdiction over the appellant, and the amount of addition made
of Rs.29,07,000 while so assuming the jurisdiction, which is bad under the
provisions of Income Tax Act, 1961 ( for short – the Act) and on the facts of
the case.
2. The learned AO, having come to know about the age and health issues of the
appellant and her husband, ought to have afforded proper opportunity in the
interest of equity and justice.

3. It is incorrect to state that the verification letter was issued to the assessee,
calling for full details of sale transaction along with resultant capital gain
/business profit was admitted, when such verification letter was never
served.
 4. The letters of verification and notice under section 148 referred to in the
Assessment Order were barred by time and therefore the same are not valid
and non-est.

5. Any other ground that may be urged at the time of hearing or before.

N. SAMPURNA