2022 (5) TMI 358

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....lowance of Rs. 35,42,719/- out of purchase expenses claimed by the Assessee. 2. In this case return of income was filed by the Assessee on 30.09.2015 by declaring total income at Rs. 1,10,30,830/- which was processed u/s 143(1) of the Act. Subsequently the case of the Assessee was reopened for limited scrutiny for the following heads: i. Large squared up loans during the year (form 3CD) ii. Large other expenses claimed in the Profit & Loss a/c. iii. Tax credit claimed (and receipts) in ITR is less than tax credit available in 26AS. iv. Mismatch in expenditure of personal nature reported in audit Report and ITR. 3. During the course of assessment proceedings, the assessee was asked to produce bills, ....

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....ertain specific bills from certain specific persons made on certain specific dates were missing. Through show cause letter the AO asked the appellant why the amounts in the bill should not be disallowed. The AO in return produced the copies of the above stated bills. On perusal of the same the AO found that some of these bills were still not proper and appeared to have been recently manufactured. The AO pointed out the below mentioned bills which were self generated and no TIN were mentioned on those bills. On one bill there has been a change of date. Bill No. Dated Name of the Party Amt. Nature of Supply   80 31.07.2014 Naresh Kumar (RMC) 2,00,000 Snd 008 28.02.2015  Ganesh Carriers 5,52,....

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....e undersigned. It is found that in the ledger bill No. etc. were mentioned and amount has been paid through bank or RTGS but the bills were raised later on papers for the same were made earlier to raising of bills which is evident from the copies of bills. This is quite an odd and unnatural situation that amount to the supplier from whom purchases were made was prepaid mentioning the bill No. whereas the bills carry the dates of a later period. Under the circumstances I am inclined with the finding and decision of the AO in disallowing the amount of Rs. 35,42,719/- from the purchase expenses claimed by the appellant. The action of the AO is confirmed." 5. Aggrieved by the impugned order, the Assessee has preferred the instant appeal. ....