TaxTMI 
TaxTMI 
2022 (6) TMI 1001
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....h credits in bank. 2. On the facts and circumstances of the case and in law, the ld. CIT(A) has erred in relying upon the additional evidences submitted by the assessee during the appellate proceedings without properly verifying the details and the material available on record. 3. On the facts and circumstances of the case and in law, the ld. CIT(A) has erred in allowing entire amount of Rs.15,11,85,776/- as explained including those credit amount also which could not be verified even during the remand proceedings since the enquiry letters issued by the AO at the address given by the assessee returned unserved." 3. On perusal of bank statement of State Bank of Travancore, account No. 67010515342, total deposits in the account was fo....
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....dia Enterprises 5,87,504.00 11. HDFC Bank A/c Balance Cheque 1,13,433.77 12. Anil Kumar Kanodia 2,04,86,291.14 13. Cash Deposit 5,90,000.00 Total 33,27,61,319.91 8. The assessee has submitted that the total credits appearing in the bank account is Rs.33,27,61,319/- as against Rs.33,71,72,552/- reported by the Assessing Officer in the Assessment Order. Further, in order to substantiate the nature and source of funds/deposits appearing in the current account, the assessee has submitted the following additional evidences under Rules 46A. i. Copy of Purchase and Sales register of m/s Ganga Traders for the period ii. Copy of VAT Returns iii. Copy of Debtors Reconciliation iv. Copy of Bank Book of M/s. Ganga Traders v....
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.... was served on the appellant on 21.12.2016 and the date of hearing was fixed for 23.12.2016, meaning thereby only two days were given for the reply of show cause. Accordingly, even if the AO would have required in the said show cause, the assessee to explain the credits in the bank account with documentary evidence, it would not have been possible for him to submit the voluminous documents in such short span of time. In this background, the assessee has pleaded that since no reasonable opportunity of being heard was given during the course of assessment proceedings. Additional evidence should be admitted at this stage. 11. The submission of the appellant was considered by the ld. CIT(A) and the additional evidences were sent to the AO for ....
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.... Ltd also appeared before the Assessing Officer and his statement was recorded on oath wherein he has confirmed the amount paid to M/s Ganga Traders on account of purchase of material and business advances during the year under consideration. The AO has further mentioned to have conducted field enquiry through his inspectors with respect to M/s Nischint Traders Pvt. Ltd. and M/s Nischint Foods Pvt. Ltd. 15. The inspector in his report has stated to have visited the registered address of the two companies and has confirmed that the two companies are active and working at the given address. The inspector has also inspected the premises of the companies and has noted the presence of employees and necessary infrastructure in the premises. 16.....