2022 (4) TMI 719

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.... in violation of natural justice. In this case the CIT(A) passed the order after giving due opportunity of hearing on following dates: - 14.08.2015, 03.12.2015, 27.07.2016, 28.09.2016, 05.01.2017, 17.04.2017, 02.08.2017, 15.12.2017, 20.01.2018, 22.03.2018, 04.12.2018, 07.02.2019, 19.02.2019 4. The assessee participated in the appellate proceedings and it cannot be said that there is any violation of principal natural justice as CIT(A) considered all arguments of the assessee's counsel and decided the issue in accordance with law. Therefore, we do not see any merit in this ground of the assessee. 5. Ground No. 4 with regard to upholding the addition of Rs. 89,500/- made towards sundry payments without any material on record an....

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....the entire set of books of account which includes several other ledgers. 8. Large volume of sundry payments have been booked in the accounts of company ZNS, which is a dummy company created for the very purpose of accounting for expenses and receipts which are otherwise not reflected in the regular books'of accounts prepared by the assessee for statutory purposes. 9. Where sundry payments ate forming part of books of accounts maintained in the names of RNS, NHL, MPC or NMCC all other entries in the cash book and in ledgers except those relating to sundry payments have been found to be reflected in the regular books of accounts prepared by the assessee for statutory purposes. 10. Large part of the cash used for....

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....emember and his replies remained evasive and non-committal. It is to be noted that document showing the sundry payment and expenditure retrieved from the computer system bear the system generated, time stamp of date of creation or modification or deletion of the document and these reveal that these documents have been created and accessed on different dates spread over several months and years thus implying that the explanation given by Shri Naveen Shetty that the sundry expenses and sundry payments had been fabricated and implanted in the computer system and else where in his office and residence by unknown persons with the aim of creating problems for M/s. RNS Infrastructure Ltd. is frivolous and untrue. The digital evidences gathered thr....