TaxTMI 
TaxTMI 
2022 (11) TMI 1299
X X X X Extracts X X X X
X X X X Extracts X X X X
....any, engaged in the business of manufacturing and sale of jute both domestic and exports. The e-return for the assessment year 2014-15 filed on 30- 11-2014 declaring income at Rs. 10,36,986/-. Case of assessee selected for scrutiny followed by serving of valid notices u/s. 143(2) and 142(1) of the Act. Various details were called by the ld. AO and submissions were filed by the assessee. After considering the same and examining the Form 3CD part of audit reports found that the assessee made sales amounting to Rs.25,90,66,090/- with the following parties: S. No. Name PAN Sale Amount 01. Mohan Jute Bags Mfg.Co. AAFFM3412R 104748831 02. Pacific Jute Ltd AACCM2063J 67645271 03. Global Exim P.Ltd AADCG....
X X X X Extracts X X X X
X X X X Extracts X X X X
....addition made u/s 68 of Rs.2,28,39,613/deemed income 3. The appellant craves the leave to make any addition, alternation, modification, etc. of the grounds either before the appellate proceedings, or in the course of appellate proceedings. 7. The Ld. Departmental Representative vehemently argued supporting the order of the ld. AO. 8. Per contra, the Ld. Counsel for the assessee vehemently argued supporting the detailed findings of the ld. CIT(A) and also various details filed in the paper book. 9. We have heard the rival contentions and perused the material placed before us. 10. Apropos the first issue regarding deletion of addition at Rs. 6,54,12,545/-, which was made by the ld. AO towards undisclosed sales for alleged....
X X X X Extracts X X X X
X X X X Extracts X X X X
....Rs.25,90,66,090 Rs. 19,36,53,545] by way of unrecorded sales of the appellant company. 3. In the appellate proceedings the Ld. AR of the appellant submitted that the AO wrongly understood the facts of the case. He pointed out that the sales made to M/s Pacific Jute Ltd aggregating to Rs.6,76,45,271/was reported by way of export sales since M/s Pacific Jute Ltd located in a notified SEZ and hence the sales thereto constituted 'deemed exports. In support thereof he furnished the ledgers of the domestic sales & export sales along with sample export invoices. He thus explained that if the sales made to M/s Pacific Jute Ltd is excluded from the sales to Indian AEs reported in the tax audit report, it shall be noted that the local sa....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... explained the alleged difference, we fail to find any infirmity in the finding of ld. CIT(A). Thus, ground no. 1 raised by the revenue is dismissed. 12. Apropos the second issue regarding deletion of addition at Rs. 2,28,39,613/-, which was made by the ld. AO towards unexplained increase in short term borrowings under the head 'advance received from the parties' to the extent of Rs. 1,29,29,108/- and increase in liability under the had 'trade payables for goods to the extent of Rs. 99,10,505/-,treated the same as income u/s. 68 of the Act. Ld. CITA) considered the submissions of the assessee including the tax audit report and other details/particulars, deleted the addition observing as follow:- (relevant extract) "3. I also fin....