2021 (2) TMI 1017

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....l. CIT ORDER Per Mahavir Singh , VP This appeal by the assessee is arising out of the order of the Commissioner of Income Tax (Appeals)-15, Chennai, in ITA No. 97/2014-15/CIT(A)-15 dated 28.12.2017. The Assessment was framed by DCIT, Company Circle VI(4), Chennai u/s. 144 r.w.s. 147 of the Income Tax Act, 1961 (hereinafter 'the Act') for the A.Y. 2006-07 vide order dated 29.03.201....

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....n the part of assessee to make a full and true disclosure of all material facts necessary for assessment as envisaged under proviso to s. 147. 3. The second issue raised by the assessee is against best judgment completed ex-parte by the AO, that no opportunity of hearing was allowed by AO and this will amount to violation of principles of natural justice. For this, assessee has raised following....

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....ming the adoption of GP ratio of unaccounted sales to turnover at 1.5% by the Respondent as taken in subsequent AY 2007-08. 8) The CIT(A) failed to have see that as per VAT Assessment Order by the CTO (FAC), Chengalpattu Assessment Circle there is no difference between Purchases and Sales and hence, estimation by the Respondent is non est in law. 5. When this appeal was called for hear....

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....d Nos. 5 & 6, reproduced above. Even on merits we noted from the order of CIT(A), that CIT(A) has not given any finding on merits except accepting the version of the AO. Now, coming to AO's order, it discussed nothing on merits and assessed the income u/s. 144 of the Act ex-parte. When these facts were confronted to Ld. senior Departmental Representative, he fairly conceded that matter can be ....