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2011 (9) TMI 146 - HC - Income Tax
Addition u/s 41(1) - unconfirmed creditors - notice u/s 147/148 - change of opinion or not - reasons to believe - Held that:- In the present case the Assessing Officer had asked specific and pointed queries with regard to the sundry creditors of Rs. 1,66,37,402/- asked for confirmations, names, addresses and details of services rendered. An addition of Rs.19,86,551/- was made for failure to furnish confirmation and explain what services were rendered by the creditors. There is no discussion, ground or reason why addition of Rs.32,97,507/- was not made inspite of the failure of the assessee to furnish conformation and details. It will be appropriate in this regard to refer to Explanation 1 to Section 147 of the Act - the contention of the assessee that the present case is of change of opinion has to be rejected. - Decided against the assessee.