1. This appeal at the instance of the assessee is directed against CIT(A)'s order dated 28.06.2019. The relevant assessment year is 2014-2015. The order of the CIT(A) arises out of the order of the Assessing Officer passed u/s. 154 of the I.T. Act.
2. The grounds raised read as follow:-
The Appellant objects to the impugned order of the Ld. CIT(A) on the grounds
1. That the impugned order of the Ld. CIT(A) is opposed to facts and law of the case insofar as it is prejudicial to the interest of the Appellant.
2. That the Ld. CIT(A) erred in confirming the order of rectification which is invalid and bad in law inasmuch as the rectification is carried out on the basis of a mere change in opinion by the Ld. AO in respect of issues that were already scrutinized in the order passed under section 143(3) and the same could not have been a subject matter of rectification under section 154.
3. That without prejudice to Ground no 2, the Appellant also objects to the impugned order for the following reasons that.
a) The Ld. CIT(A) and the Ld. AO have failed to appreciate the fact that the cash payments are made due to commercial expediency which were beyond the control of the Appellant.
b) The Ld. CIT(A) and the Ld. AO erred in not following the judicial precedents wherein it is consistently held that the expenses cannot be disallowed under section 40(A)(3) if the genuineness of the expenditure were proved.
The Appellant prays for leave to add, modify, delete or introduce additional Grounds of Appeal at any time before the Appeal is disposed off.
Based on these and such other grounds that may be adduced from time to time, the Appellant requests the Honourable Income Tax Appellate Tribunal to consider the petition in the light of principles of justice and cancel the addition made by the Assessing Officer."
3. The brief facts of the case are as follow: