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2016 (2) TMI 944

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..... book results by the Assessing Officer is confirmed, reliance is being placed on the transactions traversing the cash book, irrespective of their notations, since amongst the inflow and outflow of cash, tax payments made by the appellant are independent and verifiable. Consequently, no separate addition is required to be made on account of purchases or expenditure. The Assessing Officer is directed to work out the peak from the entries in the cash book, including bank transactions, of the appellant for the relevant year and make a singular addition of the said amount, as unexplained investment/expenditure - Decided against revenue - ITA No. 447/Del/2014 - - - Dated:- 10-2-2016 - SH. C.M. GARG, JUDICIAL MEMBER AND SH. O.P. KANT, ACCOUNTAN .....

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..... hapar Home Group of cases having allegation of floating the company with dummy directors and shareholders. The Assessing Officer further observed that capital was formed in these companies in the form of reserve and surplus over the years and was invested in the stock of textile and whenever cash was required the stock were sold and the money was utilized for other purposes as per their requirement. The Assessing Officer noticed that in the year under consideration the assessee company shown purchase of textile goods of ₹ 35,84,684/- and sales of ₹ 39,41,814/- resulting into profit of ₹ 12,433.99/- The Assessing Officer further asked the assessee to prove its trading activity and produce sales tax record. In response, the .....

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..... ment in expenditure. The relevant paras (para nos. 6.15 6.16) of learned Commissioner of Income Tax (Appeals) are reproduced as under: 6.15 Therefore, contrary to the claims of the appellant, what is obvious and discernible is that the appellant was one of the several entities in the whole scheme of network of companies, belonging to the Thaper-Dhingra Group which were used to infuse unaccounted money in other companies of the group, through a well orchestrated arrangement of seemingly accounted transactions, emanating from their audited financial statement, but where in reality, the only activity was of book building . In these circumstances, the claim of audited books notwithstanding, the book results are required to be rejec .....

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