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TMI Blog2020 (7) TMI 600X X X X Extracts X X X X X X X X Extracts X X X X ..... ed its return of income for Assessment Year 2020-11 declaring income of Rs. 1.60 crore. The return of income was selected for scrutiny and assessment was completed under section 143(3) on 14.03.2013 accepting the return income. Subsequently, case was reopened under section 147. The assessing officer reopened the case on the basis of information received from the DGIT (Inv.), Mumbai, who in turn received information from the Sales Taxes Department Government of Maharashtra that certain dealers were engaged in providing the accommodation entry without actual delivery of goods. The assessee is one of the beneficiaries of such accommodation entry. On the basis of such information, the Assessing Officer made his opinion about the re-opening of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d. CIT(A), the revenue has filed the present appeal before us. Though the revenue has raised as many as seven grounds of appeal, however, in our view the sole and substantial ground of appeal is that "if the ld CIT(A) erred in restricting the disallowance of bogus purchases to the extent of 12.5%". 4. We have heard the submissions of the ld. Departmental Representative (DR) for the revenue s and the learned Authorised representative (ld AR for the assessee and also carefully perused the order of the tax authorities below. The ld. DR for the revenue supported the order of Assessing Officer. The ld. DR submits that the investigation wing of the income tax department made full-fledged investigation about the modus operandi of the hawala trade ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... idered the rival contention of both the parties and perused the order of lower authorities. We have noted that after re-opening of the assessment, the Assessing Officer proceeded for re-opening. The assessee field its reply to the show-cause notice issued by Assessing Officer, vide its reply dated 23.02.2016. We have noted that the Assessing Officer has not referred the contents of reply filed by assessee. The assessee in the statement of fact before ld CIT(A) claimed that evidences with regards to ledger accounts and the payments through banking channel were provided to the assessing officer. We have seen that the assessing officer has not made any independent investigation. The books of account of assessee were not rejected. The Assessing ..... X X X X Extracts X X X X X X X X Extracts X X X X
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