2021 (8) TMI 273

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....e action of the A.,O. of rejecting the books of accounts for the reason that the compliance have not been given by the transporter parties to whom notices u/s 133(6) of I.T. Act were issued. Even though complete address and contact details of Transporter parties were provided to the Ld. A.O. and to Ld. CIT(A) by the appellant, the audited books of account have been rejected u/s 145(3) of I.T. Act on this ground without finding any mistake in books of account whatsoever. It is submitted that the books result be accepted and the addition made of Rs. 13,50,927/- be deleted. 2. The learned CIT(A) has erred in law and on facts in confirming the addition of Rs,13,50,927/- by taking average net profit for 3 years and rejecting books of account ....

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....y rejecting the books of account. Accordingly, the Assessing Officer has made an addition of Rs. 13,50,927/- to the total income of the assessee. 4. Aggrieved assessee has filed appeal before the ld. CIT(A). The ld. CIT(A) sustained the addition stating that two creditors Ms. Priyanka Transport Rs. 17,11,004/ and Mr. Sanjay R. Dhaitidik Rs. 5,44,940/- remained unverified. 5. During the course of appellate proceedings before us, the ld. counsel contended that assessee has furnished the full details of transactions along with PAN No. office addresses, copies of ledger accounts and the detail of repayment made through banking channel before the Assessing Officer and the ld. CIT(A) in support of her claim. The ld. counsel has referred page no....

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....and copies of the invoices issued by these parties. The assessee has also submitted the copies of ledger accounts of current year and the subsequent year. The assessee has also submitted the emails and also the proof of sending mails to these parties to make compliance with the notices issued by the Assessing Officer. During the course of assessment, the assessee has also submitted the complete assessment detail, PAN No and the bank statement showing the payment made to Priyanka Transport and Sanjay R. Dhaitidik for F.Y. 2011-12 and F.Y. 2012-13. The Assessing Officer has treated the transportation expenses pertaining to these parties as bogus only on the basis of non-compliance made by these parties to the summon issued by the Assessing Of....