2013 (12) TMI 410

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....for scrutiny and statutory notices were issued. No details were furnished and nobody attended for hearing. The assessment was completed u/s 144 of the Act. 3. During the year under consideration, the assessee had shown sales of agricultural produce to the tune of Rs. 35,73,30,388/- on which total income return was Rs. 2,93,898/-. The percentage of net profit shown by the assessee was less than 0.1%. The AO held that the assessee company failed to substantiate the profit shown by it by producing books of account, vouchers and other details called for and, hence, the correctness of purchases and other expenses claimed could not be verified. The AO, therefore, rejected the book results shown by the assessee and estimated the net profit i....

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..... The assessee pointed out that for the year consideration the books of account, vouchers, etc. were lost in fire accident. The assessee argued that the AO did not consider the facts of the case or even the basis of the scrutiny assessments made in the earlier years in the assessee's case itself. 6. After considering the submissions of the assessee, the CIT(A) observed that the plea with respect to the destruction of books of account in the fire accident, had been raised by the assessee only during the course of the appellate proceedings before him and no such claim was made at the assessment stage, therefore, the AO had reason to believe that the assessee consciously declared such lower rate of profit. The CIT(A) held that nothing was b....