9911796707
TMI Blog2021 (6) TMI 1035X X X X Extracts X X X X X X X X Extracts X X X X ..... cause of disallowing of following expenses on lump sum basis without the support of any material either collected or placed upon records, having any nexus thereto, confirming either to the extent of its disallowance the expenditure was never incurred or were not having any relation to the income earned:- a. Purchases - Rs. 3,00,000/- b. Wages & Salary -Rs. 2,00,000/- c. Other Expenses -Rs. 27,103/- 2. That the disallowance of expenses on lump sum basis are further wrong because no opportunity if any was ever afforded prior presuming to be its disallowance thereof on lump sum basis. Besides this, no material if any was ever confronted forming any basis or nexus to the extent of its disallowance thereof. 3. That the addition of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... AT in the appellant's own case for the Assessment Year 2011-12. 7. That charging of interest u/s 234B of the Act, is further against the law and to the facts of the case, as being contrary to the additions made in the declared income. 8. That the appellant assails his right to amend, alter, change any grounds of appeal at any time even during the course of hearing of the instant appeal. PRAYER: It is, therefore, prayed: 1. That illegal and impugned additions made of Rs. 7,63,700/- in the declared income, may please be deleted / quashed. 2. That charging of interest u/s 234B of the Act, may please be quashed / deleted being consequential to the additions made and relief claimed there from. 3. That any other relief which ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ne by the Assessing Officer and the order relied by the Ld. AR cannot be applied in the present assessment year as each assessment year is a separate assessment year and the factual aspects are different. 7. We have heard both the parties and perused the material available on record. From the perusal of the Tribunal's decision in assessee's own case for Assessment Year 2011-12, Ground No. 2 is related to unverifiable purchases. In the present case, the assessee was asked to reconcile the difference in respect of receipts amounting to Rs. 25,40,955/- by the Assessing Officer during the assessment proceedings. Merely maintaining the books of accounts and not giving a plausible explanation regarding the purchases, the same cannot be stated th ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
