2018 (12) TMI 210

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ing total income of Rs. 12,92,240/-. The case was selected for scrutiny and the assessment was completed on total income of Rs. 16,32,380/-. Subsequently, the Ld. Pr. CIT, Guntur has called for the records and has taken up the case for revision and found that the assessee has over stated the purchases compared to the VAT returns. According to the VAT return, the total purchases were Rs. 1015,34,67,656/- against which the purchases debited to the profit and loss account was Rs. 1015,39,00,057/- resulting in excess claim of expenditure under the purchases to the extent of Rs. 4,32,401/-. Therefore, viewed that the assessment made u/s 143(3) was erroneous and prejudicial to the interest of the revenue and accordingly issued the notice u/s 263 ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

..../3) : 70,69,76,006 (-) 21,67,033 Omission to report the invoice No. 1042 dated 28. 03. 2013 of Chandra Anjaiah Parameshwar, Sec'bad Under reporting due to clerical errors and omission Rs. (-) 6,21,467   The assessee further submitted that all the purchases are accounted in the books of accounts, produced the vouchers and the AO verified the reconciliation statement as well as the purchases, therefore argued that there was no error in the assessment order which required to be modified or revised. The Ld. Pr. CIT considered the explanation offered by the assessee and observed that as per the e-returns, the difference was only Rs. 4,32,401/-, whereas the difference worked out by the assessee was at Rs. 6,21,467/- which i....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... heard both the parties and perused the material placed on record. In this case, the assessment was completed u/s 143(3). During the assessment proceedings, the AO has called for the details and verified the same. The Ld. AR placed page No. 37 of the paper book wherein the AO had issued the notice u/s 143(2) and furnished the details vide page No. 38-42 of the paper book. The Ld. AR referring to page No. 8 of the paper book submitted that as per the trading account, there were purchases of copper in silver articles account for an amount of Rs. 1,88,977/- and in Gold Jewellery account, the copper purchases were 118/-. Aggregate of copper purchase of Rs. 1,89,060/- was the difference referred by the Ld. Pr. CIT in para No. 5. 2. of the revisi....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....complete details of the purchases before the AO and explained the difference of Rs. 6,21,497/- which consists of difference in purchase of gold jewellery, silver of Rs. 4,32,401/- and the copper purchases of Rs. 1,89,060/- and the same was examined by the AO and accepted the trading results. From the above discussion it is clear that the difference purchases account was Rs. 6,21,497/- but Rs. 4,32,401/- as observed by the Ld. Pr. CIT and the details of the same is as under : Difference in Gold Jewellery Purchases - Rs. 4,32,401/- Add Difference in Coppoer Purchases - Rs. 1,89,060/- Total - Rs. 6,21,497/- The AO called for the details and verified the same and found that the assessee has accounted the purchases correctly....