TMI Blog2023 (5) TMI 1110X X X X Extracts X X X X X X X X Extracts X X X X ..... y the Revenue against the order of the Ld. Commissioner of Income Tax (Appeals)-30, New Delhi dated 28.04.2022 for the AY 2018-19 in deleting the addition of Rs.2,12,14,164/- made u/s 68 of the Act. 2. Briefly stated that facts are that the assessee e-filed his return of income on 17.09.2018 declaring income of Rs.45,88,710/- for the assessment year under consideration. The assessment was completed u/s 143(3) on 19.04.2021 determining the income of the assessee at Rs.2,58,02,871/-. In the course of assessment proceedings, the assessee was required to furnish the details of sales made by the assessee for the financial year relevant to the assessment year under consideration as the assessee has shown sales only for April to June 2017 only ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d the profit declared by the assessee from the transactions of sales and purchases and he has not doubted the purchases made during the year. Ld. Counsel submits that when purchases and profit as computed by the assessee or accepted there are no reasons to doubt the sales made by the assessee. Ld. Counsel submits that the payments received from the five parties were received by a banking channel and in support of this the assessee filed bank statement which is also placed at paper book pages 43 to 48. Ld. Counsel further submits that as a matter of fact the AO accepted in the assessment order that after the introduction of GST from July 2017 the assessee did not carry out any business. Therefore, the Ld. Counsel submits that since the asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ant during the assessment proceedings as well as a during the appellate proceedings has submitted that the PAN of parties in respect of sales amounting to Rs. 2,12,14,164/- out of total sale of Rs. 28,12,16,947/- could not be provided by him, but it cannot be the ground for treating the sales bogus and adding the same under section 68 thereby taxing him twice firstly as a sales declared by the appellant secondly by adding the same sales under section 68 as cash credit. 9.1 The applicant had further stated that the sales made by him are genuine sales, the payments in respect of the sales had been received via banking channels and has been duly recorded in the books of the appellant. He has also stated that the appellant has paid VAT on ..... X X X X Extracts X X X X X X X X Extracts X X X X
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