TMI Blog2023 (3) TMI 862X X X X Extracts X X X X X X X X Extracts X X X X ..... petitioner that it made payments in the course of business was not accepted. AO has specifically recorded that the proprietor Smt. Seema Gupta has accepted that her firm was not engaged in real business activities. This Court is of the view that merely filing of VAT returns cannot be held to establish genuineness of transaction especially when it was not shown that the VAT Department had made a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... under Section 148A(d) of the Act for the Assessment Year 2014-15. 2. Learned counsel for the Petitioner states that the impugned order is arbitrary and cryptic since sum of Rs.1,18,000,000/- is held to have escaped assessment without considering that no accommodation entry was taken by the Petitioner. He states that the business of trading in chemical and other allied goods and the transaction ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... order the Assessing Officer has specifically recorded that the proprietor Smt. Seema Gupta has accepted that her firm was not engaged in real business activities. This Court is of the view that merely filing of VAT returns cannot be held to establish genuineness of transaction especially when it was not shown that the VAT Department had made any physical or spot enquiry. Moreover, neither M/s See ..... X X X X Extracts X X X X X X X X Extracts X X X X
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