TaxTMI 
TaxTMI 
2022 (3) TMI 293
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.... passed u/s. 143(3) r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred to as Act) dated 30/03/2015 by the ld. Dy. Commissioner of Income Tax-11(2)(1), Mumbai (hereinafter referred to as ld. AO). 2. Though the assessee has raised several grounds, the only effective issue is to be decided in this appeal is disallowance made on account of bogus purchases. 2.1. We have heard the rival submissions and perused the materials available on record. We find that the ld. AO had made addition @100% on the value of purchases treating it as in genuine, whereas the ld. CIT(A) had restricted the same to only the profit percentage of 3%. We find that the Revenue is aggrieved against the order of ld. CIT(A) for restricting the disallowance of ....
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.... recorded by the ld. AO were sought for which was duly furnished to the assessee by the ld. AO. Subsequently notice u/s. 143(2) of the Act was issued by the ld. AO on 22/09/2014 which was served on the assessee on 25/09/2014. Later notice u/s. 142(1) of the Act together with detailed questionnaire was also issued and served on the assessee calling for requisite details. The ld. AO observed that assessee had declared total purchases of Rs. 50,93,64,553/- during the year under consideration. The assessee gave a complete list of purchases together with sample bills thereon from the ld. AO. It is not in dispute that assessee had made purchases from the following parties:- Sr.No. Name of the bogus entry provider Amount (Rs) 1 AVI ....
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....tion dated 9th January, 2014. The Assessee company is producing herewith Stock Register Book wherein the entries of the goods purchased and the same are utilized for manufacturing of the jewellery and sales made of these items. Hence no reliance can as such be placed on his earlier statement which is only on the basis of the present reassessment. Mr. Rajendra Jain & Mr. Mudit Karnawat have also made affidavits wherein they have duly confirmed that they have sold the diamonds to the Assessee firm and received the sale proceeds from the assessee firm confirming that the goods were actually sold to us -copies enclosed and originals available for verification. Consequently, a subsequent statement on oath would carry more credence compa....
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....issue of notices u/s. 133(6) of the Act which could not be served due to the following reasons as tabulated hereunder:- Sr.No. Name of the party Remarks 1 Super Jewels Office was found closed since a very long time 2 Cartier Jewels Tara Niwas has been taken for complete repairs and no one present at the said premises 3 Royal Diamond Pvt Ltd Tara Niwas has been taken for complete repairs and no one present at the said premises 4 Uniquestar Gems (I) FM Ltd Tara Niwas has been taken for complete repairs and no one present at the said premises 5 Mayur Gems Found to be closed, served by affixture 6 Mangalam Exports Found to be dosed, served by affixture 7 Shikha Diamonds Pvt Lt....