2022 (9) TMI 500

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....nt was filed. I have noted from order of the authorities below that the assessee has remained non-cooperative in both the assessment proceedings before the AO, who consequently passed exparte order under section 144 of the Act and even before the ld.CIT(A) where only written submissions were filed, on the basis of which the ld.CIT(A) passed his order, noting consistent noncooperative attitude of the assessee.In the light of the fact that even today, despite notice of hearing being served to the assessee, none appeared nor any application seeking adjournment was filed, it appears that the assessee is in the habit of not pursuing its appeal. Therefore it was decided to proceed with the matter exparte. 3. Sole issue raised by the assessee r....

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.... as under: "5.3 It is seen that during the assessment proceedings, the appellant was asked (i) month-wise consumption of raw material, production and wastage in quantity and value., month-wise consumption of power in units and valuer, (iii) working of GP and reason for fall in GP, (iv) produce stock register for verification, etc, but no details were filed by the appellant. During the appellate proceedings, the appellant filed certain details regarding electricity consumption, statement of stock, trading account, audit report etc., which are examined. The appellant has given the reason for low profit during the year as below - ".. .Further issue raised by the Ld AO is regarding Low Profit Before Tax (PBT). In this context,....

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....) noted that the submissions and reasons given by the assessee for the low profit during the year was very general in nature and nothing specific had been filed by the assessee explaining the reasons for the huge losses returned. He further noted from the financial accounts of the assessee that while opening stock of Rs.4.8 crores and purchases of Rs.6.62 crores raw-material were shown by the assessee, the closing stock was reflected at NIL. He further noted that stock statement in quantity and value did not show any consumption of opening raw-material and purchase rawmaterial. He therefore held that valuation of the stock by the assessee could not be relied upon. Accordingly, he upheld rejection of the books of accounts and the assessee an....

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..... 1,88,79,846. Therefore, the valuation of stock by the appellant cannot be relied upon. In view of the above discussion, the details and explanation given by the appellant is hereby rejected and the findings of the assessing are upheld. Therefore, the ground of appeal regarding the assessment of the net profit is hereby rejected." 6. I have gone through the order of the ld.CIT(A) and I do not find any infirmity in the same. The assessee has at no point of time given any proper explanation for the huge loss returned by it in the impugned year more particularly when there were profits returned in the preceding year. The explanation furnished ,as reproduced above has been rightly found to be general in nature by the Ld.CIT(A) the ....