2022 (3) TMI 1234

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....n the nature of trade creditors. On perusal of details furnished by the appellant, it is noticed that opening balance of ten creditors, in respect of which addition has been made by the AO, the opening credit balance as on 01.04.2014 was Rs. 2,78,96,356/-. The AO has made addition of Rs. 3,68,85,701/- on account of unexplained credit u/s. 68 of the Act. It is observed by the AO that notice u/s. 133(6) was issued to various sundry creditors to ascertain their creditworthiness and most of the creditors have not replied with satisfactory explanation except few. In this connection, it is submitted by the appellant that in show cause notice dated 19.12.2017 issued u/s. 142(1) of the Act, the AO has mentioned as under: "1. On perusal of ....

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.... documents furnished by the appellant which also included letters furnished with the AO on different dates during the course of assessment proceedings. The appellant had submitted confirmed copy of ledger account of all the creditors with the AO in the month of May, June and September, 2017. It is submitted that reply to 133(6) notice was received from the following parties: i) Jai Shree Mills ii) Mohan Lai Chander iii) Moorti Fashion 5. The appellant furnished reconciliation of accounts with the above mentioned parties during the course of assessment proceedings. Further, notice u/s. 133(6) were issued to M/s. Atiksh Trading, Narayan Impex, Rainbow Enterprises and Shree Senthil Mills but no reply was received from the said part....