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2023 (10) TMI 1020

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..... ent projects qua school buildings during the year. We note that the copy of the certificate of completion of the said works from the Executive Engineer, Social Sector, PW Directorate and PW(CB) Directorate were furnished certifying that the material purchased has been used in the construction of these buildings. We also note that the assessee has filed all the evidences before the AO as well as be .....

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..... o Ld. CIT(A) ] dated 18.07.2023 21.06.2023 for the Assessment Years (in short AY ) 2013-14 2014-15, respectively. First, we take ITA No. 828/KOL/2023 for AY 2014-15. 2. The issue raised in ground no. 3 is against the confirmation of addition of Rs. 1,32,877/- being 7.99% of the disputed purchases by Ld. CIT(A) as made by the Assessing Officer (in short ld. 'AO') u/s 69C of the Act .....

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..... t of the investigation wing to the effect directors of M/s. Gajgamini Sales Pvt. Ltd. and M/s. Raipur Trading Pvt. Ltd. having admitted to be involved in providing accommodation entries, treated the purchases made from these entities as bogus and called upon the assessee as to why the said purchases should not be added to the income of the assessee. The assessee replied the said show cause by subm .....

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..... he Act in the assessment framed. 4. In the appellate proceedings, Ld. CIT(A) simply confirmed the order of the AO on the same reasoning without considering the contentions and arguments of the assessee. 5. After hearing the rival contentions and perusing the material on record, we find that the assessee has executed a Government projects qua school buildings during the year. We note that the .....

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..... ounds were not pressed at the time of hearing and accordingly, they are dismissed as not pressed. 7. In the result, the appeal filed by the assessee is allowed. Now, we take ITA No. 827/KOL/2023 for AY 2013-14. 8. The issue raised in ITA No. 827/KOL/2023 is similar to one as decided by us in ITA No. 828/KOL/2023. Therefore, our decision in ITA No. 828/KOL/2023 would mutatis mutandis apply .....

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