2020 (4) TMI 406

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....ts and circumstances of the case, learned CIT(A) has erred, both on facts and in law in rejecting the contention of the assessee that the initiation of the reassessment proceedings and the reassessment order are bad, both on the facts and in law and liable to be quashed, as the statutory conditions and procedure prescribed under the statute have not been complied with. 3 (i) On the facts and circumstances of the case, learned CIT(A) has erred, both on facts and in law in rejecting the contention of the assessee that the reassessment proceedings initiated by the AO are bad in the eyes of law, as the reasons recorded for the issue of notice under section 148 are bad in the eyes of law and are contrary to the facts. (ii) On the facts and....

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....the quantity purchased and sold being completely tallying, the allegation that the assessee has not made purchases cannot be sustained. 7. On the facts and circumstances of the case, the learned CIT(A) has erred, both on facts and in law in confirming the addition on account of bogus purchases, despite their being adequate material and evidences brought on record by the assessee before the AO to show that the purchases and sales were made in the regular course of business. 8. On the facts arid circumstances of the case, the learned CIT(A) has erred, both on facts and in law in rejecting the contention of the assessee that the addition so made on the basis of material collected at the back of the assessee, is bad in law and liable to b....

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....ta and Sh. Vishesh Gupta have admitted to have provided accommodation entries in their statements recorded during the course of search proceedings u/s 132 and thereafter in the statements recorded by ACIT, Central Circle-10, New Delhi on 12.02.2013 and 04.02.2013 respectively. It was also stated that these persons have also filed affidavits in which they have confirmed that they were not making any actual sales but were issuing bogus purchase bills to provide accommodation entries. The appellant was asked to show cause why these purchases booked by the appellant amounting to Rs. 7,44,644/- be not treated as bogus purchases and be not added to the total income. The AO had also issued summons u/s 131 of the Act to Sh. Rakesh Gupta and Sh. Vis....