9911796707
TMI Blog2021 (11) TMI 499X X X X Extracts X X X X X X X X Extracts X X X X ..... its appeal and they are extracted herein below for reference: "1. The order of the Ld. CIT(A)-6 is contrary to law and facts. 2. The Ld. CIT(A) erred in holding that the notice U/s. 148 was issued after satisfying the conditions precedent for the issue of the said notice and that the notice is valid. 3. The Ld. CIT(A) erred in rejecting the appellant's plea that the notice U/s. 148 was issued without any tangible material and without any live link between reasons recorded and belief that income chargeable to tax escaped assessment. 4. In the facts and circumstances of the case the notice issued U/s. 148 stands vitiated as the conditions precedent for the issue of said notice have not been fulfilled. 5. The Ld. CIT(A) erred in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o be condoned so as to make way for the cause of substantial justice. We accordingly hold that assessee's impugned delay of 55 is neither intentional nor deliberate but due to the circumstances beyond its control. The same stands condoned. Case is now taken up for adjudication on merits. 4. Coming to the assessee's twin substantive grounds inter alia challenging validity of reopening as well as both the lower authorities' action treating it's purchases of Rs. 42,18,510/- from M/s. Kangan Jewellers Private Limited as bogus, it is noticed that the very issue had arisen it's appeals ITA No. 755 to 757/Hyd/2017 decided partly in its favour on 18/08/2021 pertaining to preceding assessment years as follows:- "3. It further ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... respective detailed discussions justifying the impugned re-opening(s) based on the Investigation Wing, Mumbai's information pinpointing the specific inputs in search proceedings including M/s. Bhanwarlal Jain group authorised persons statement(s) to have been providing bogus accommodation entries. We therefore hold that the Assessing Officer had rightly initiated the impugned re-opening process in all these three cases. The assessee fails in its identical first and foremost ground therefore. 6. Next comes equally important aspect of quantification of the impugned bogus purchases disallowances/additions of Rs. 9,04,500/-, 20,05,500/- and Rs. 25,48,900/-; respectively. The assessee's argument before us is that once its corresponding ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
