TMI Blog2018 (12) TMI 123X X X X Extracts X X X X X X X X Extracts X X X X ..... addition regarding estimation of sales, job work income and other income, it is observed that Ld.A.O. has not given any reason for estimation. CIT(A) has recorded that even during remand proceedings A.O. has not made any enquiries and no comments have been given regarding books of accounts maintained by assessee. It is very much categorical to observe that sales has not been doubted by A.O. AO observed therein that, mere filing PAN numbers or assessment particulars, VAT returns and copy of sales tax RC etc., do not establish identity of persons. He further notes that actual and true identity of persons or company was business undertaken by them. PAN numbers/registration of VAT are allotted on basis of application, without actual defacto ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pellant craves to be allowed to add any fresh grounds of appeal and/or delete or amend any of the grounds of appeal. 2. Brief facts of the case are as under: Assessee filed its return of income on 11/10/10 declaring total income of ₹ 73,70,807/-. The case was selected for scrutiny and notice under section 143 (2) of the Act along with notice under section 142 (1) and questionnaire was issued to assessee. In response to statutory notices, after a considerable delay, representative of assessee appeared before Ld. AO and filed requisite details as called for. 3. Ld. AO recorded that assessee failed to produce books of accounts for verification of purchases nor have filed any copies of accounts of persons from whom the p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ansportation of goods from the destination of seller to the destination of assessee. iv) In some cases whole of amount of purchase was shown as creditors at the end of the year and the assessee has not produced any evidence to discharge its onus to explain the amount of creditors as appearing in its books of account. v) Vide summons under section 131 and notices under section 133(6), 20 entities were required to attend this office of confirm the purchases made by the assessee company, but no such person attended in compliance to summons. Report of Inspector of this office, who was deputed to find out about genuineness of such entities, is self explanatory as tabulated above. vi) Wherein replies have been received, only copies ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tails. (iv) Bank statements were also produced for verification of payment through cheques. Original bills were also produced for their verification. 8. It was submitted that, assessee is engaged in execution of work orders, awarded by Government departments, hospitals, and makes purchases from various parties, which usually differs from work to work and year to year. He submitted that it is admitted fact that, purchases were made on strength of duly issued tax invoices, that contains TIN number and other details, which were produced before Ld. AO. Regarding non-compliance of confirmation of purchases, Ld.AR submitted that verification of books of accounts contained complete vouchers, purchase bills which were produced before Ld.AO ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . We therefore uphold the view of Ld.CIT(A) in accepting books of account of assessee. 11. Insofar as addition regarding estimation of sales, job work income and other income, it is observed that Ld.A.O. has not given any reason for estimation. Ld.CIT (A) has recorded that even during remand proceedings Ld.A.O. has not made any enquiries and no comments have been given regarding books of accounts maintained by assessee. It is very much categorical to observe that sales has not been doubted by Ld.A.O. Ld.CIT (A) accepted claim of assessee by observing as under: 6.4 the appellant had submitted before several documents like confirmation from parties, copies of purchase bills, original bills, bank statements, copy of Ledger accounts. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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