9911796707
TMI Blog2022 (10) TMI 1218X X X X Extracts X X X X X X X X Extracts X X X X ..... sue of a computer-generated Document Identification Number (DIN) and quoting of the same in the body of such communication, by any income-tax authority relating to assessment, appeals, orders, statutory or otherwise, exemptions, enquiry. investigation, verification of information, penalty, prosecution, rectification, approval etc. to the assessee or any other person, on or after the 1st day of October, 2019, failing which such communication shall be treated as invalid and shall be deemed to have never been issued 2. On the facts and in circumstances of case and in law, the Ld CIT(A) erred in estimating the profit from alleged Hawala purchases being Rs. 4,22,145/@ 12.50% of the alleged bogus purchases of Rs. 33,37,160, based on the informa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of case and in law, the L.d. CIT(A) erred in by confirming an Ad Hoc addition of Rs 75,000/- on account of lower household withdrawal considering the status of the appellant and his standard in the society. 7. On the facts and in circumstances of case and in law, the Ld. CIT(A) erred by confirming an Ad Hoc addition of Rs 50,000/- on account of various expenses which were allegedly not fully verifiable 8. On the facts and in circumstances of case and in law, the Ld CIT(A) erred in not following the ratio of jurisdictional ITAT and the High Court, according to which only profit element embedded in the alleged bogus purchases can be taxed and not the whole of the alleged bogus purchases, 9. The Ld CIT(A) has erred on the facts of the ca ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... i.e M/s Abhishek Enterprises complied with the notice issued u/s 133(6) and stated that he did not have any transaction with assessee and other 7 parties had not made compliance with the notices issued by the A.O. Therefore, the A.O asked the assessee to produce the parties before him to prove the genuineness of the transaction but the assessee failed to in doing so, therefore, the A.O had disallowed an amount of Rs. 80,08,830/- on account of bogus purchases. The A.O has further noticed that assessee had shown outstanding sundry creditors amounting to Rs. 78,53,348/-. The A.O had issued notices u/s 133(6) to these parties but they have also not made any compliance with the notices issued by the A.O. The assessee was asked to produce these ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dition of Rs. 64,17,345/- made by the A.O was confirmed in respect of such creditors. In respect of addition of Rs. 75,000/- and Rs. 50,000/- on account of household withdrawal and expense incurred in cash the assessee has not submitted any detail before the CIT(A), therefore, the ld. CIT(A) has confirmed such additions. 6. During the course of appellate proceedings before us neither the assessee has attended nor submitted any detail, therefore, after hearing the ld. D.R and after taking into consideration the material on record, we consider that in respect of bogus purchases the assessee had not produced an supporting documents in the form of delivery challan, lorry receipt stock register in support of such purchases, therefore we don't f ..... X X X X Extracts X X X X X X X X Extracts X X X X
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