2018 (11) TMI 504

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....AL (ACCOUNTANT MEMBER) 1. The captioned appeal by assessee for Assessment Year [AY] 2011-12 contest the order of Ld. Commissioner of Income-Tax (Appeals)-54 [CIT(A)], Mumbai, Appeal No. CIT(A)-54/IT-714/ITO- 19(1)(4)/2015-16 dated 22/12/2017 qua confirmation of certain additions on account of alleged bogus purchases. The assessment for impugned AY was framed by Ld. Income Tax Officer 19(1)(4), ....

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....e bills and it was noted that the assessee stood beneficiary of such bogus purchase bills to the tune of Rs. 1,10,24,932/- from five such entities, the details of which has been extracted in para-2 of the quantum assessment order. Consequently, statutory notice u/s 148 dated 28/02/2014 was issued to the assessee which was followed by notices u/s 143(2) and 142(1). During impugned AY, the assessee ....

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....lleged bogus purchases. Still aggrieved, the assessee is in further appeal before us. The Ld. DR, Ms. N.Hemalatha supported the stand of lower authorities. 4. We have carefully considered the submissions and material on record. So far as the legal grounds raised by assessee, we find that the original return was processed u/s 143(1) and therefore, the only requirement to initiate the reassessmen....

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....same time, the assessee could not conclusively substantiate the delivery of material and failed to produce any of the party to confirm the transactions. Notices issued u/s 133(6) elicited no satisfactory response. All these factors cast a serious doubt on assessee's claim. Therefore, in such a situation, the addition, which could be made, was to account for profit element embedded in these purc....