2021 (9) TMI 1084

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....layed filing of this appeal. The reasons stated in the Affidavit for belated filing of this appeal is that the assessee for identical relief sought in this appeal had also filed a rectification application before the first appellate authority within the specified period. It was stated that the CIT(A) directed the assessee to file rectification application electronically, and since it was not possible to file rectification application electronically, the assessee filed this appeal within the short period (immediately when it was realized that the rectification application cannot be filed electronically). Therefore, it was prayed that the delay in filing this appeal is unintentional and out of bonafide belief that the prayer of the assessee w....

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.... Officer, during the course of assessment proceedings, noticed difference in purchase by the assessee from M/s. Ajay's Bangalore. The total purchases by the assessee from M/s. Ajay's Bangalore as appearing in assessee's books was Rs. 45,07,570, whereas, as per the extracts of accounts received from M/s. Ajay's Bangalore was Rs. 38,74,182. After taking into consideration the creditors to the extent of Rs. 2,53,528 and non-granting of discount of Rs. 4,495, the Assessing Officer made an addition of Rs. 3,84,730 stating that the difference is on account of suppression of purchases. 5. Aggrieved by the addition of Rs. 3,84,730, the assessee preferred an appeal to the first appellate authority. Before the first appellate autho....

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....Officer and the CIT(A). 8. I have heard rival submissions and perused the material on record. The assessee has filed abstracts of assessee's transaction with M/s. Ajay's Bangalore for the year ending 31.03.2006 (abstract of transaction in assessee's books as well as in the books of account of M/s. Ajay's Bangalore). The alleged difference between the two accounts (M/s. Ajay's Bangalore and assessee) as on 31.03.2006 was reconciled after the close of the accounting year. The differences were due to certain accounting discrepancies in the books of account of the assessee as well as M/s. Ajay's Bangalore. The difference cannot be termed as suppression of purchases in the strict sense. According to the assessee, the d....

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....ngalore, as appearing in the appellant's books of account, for the financial year 2006-07 reflects a sum of Rs. 67,544/- was accounted as income for the A.Y. 2006-07 by way of discounts and rebates from M/s. Ajay's Bangalore - Refer ledger account at marked pages 77 to 83 and at pp 82 and 83 of the paper book. 9. The copy of the printout of ledger account of M/s. Ajay's Bangalore, as appearing in the appellant's books of account, for the financial year 2007-08 reflects a sum of Rs. 6,79,462/- was accounted as income for the A.Y. 2008-09 by way of discounts and rebates from M/s. Ajay's Bangalore. Refer ledger account at marked pages 90 to 94 and at pp 94 of the paper book." 8.1. If the contention of the assess....