2021 (12) TMI 1437

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....erives income from manufacturing of hosiery goods on job work basis and trading of yarn, fibers, knit ted fabrics, cotton cloth and raw cotton etc. The return of income for the year under consideration was filed declaring income at 'nil'. The case was selected for scrutiny under CASS. During the course of assessment proceedings, the Assessing officer noted that there was a loss in trading of cotton cloth as the assessee had purchased cotton cloth @ Rs. 663.76 per Kg of average purchase price and had sold it on lower average sale price at Rs. 657 per kg. The assessee was asked to explain the reason for such loss. It was the assessee's content ion that the assessee had wrongly posted the sale bill of cotton cloth in raw cotton account and, th....

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.... and on the facts while coming to a conclusion that wrong classification of sale of cotton cloth into the sale of raw cotton is a suppressed sales of cotton cloth. 3. The assessee craves leave to add, alter, modify and amend the ground of appeal . 3.0 The Ld. Authorised Representative (AR) submitted that the allegation that the assessee could not explain the difference and that the wrong posting of the sale of cotton cloth could not be substantiated by the assessee was incorrect . It was submitted that all the relevant details including the day to day purchase details were filed before the Assessing officer. The Ld. AR also submitted that subsequently the assessee has also obtained a Certificate from the Chartered Accountant (C.....

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....ritten submissions filed by the assessee in this regard and it cannot be said that the assessee has not submitted any documentary evidences in support of its claim. The only thing lacking perhaps was the inability of the assessee to properly explain the entries. However, it cannot be said that no documents or evidences were furnished by the assessee. We have also gone through the Certificate dated 27.3.2021 issued by M/s S. Karan Shama & Co. , C.As, Ludhiana placed at page 8 of the paper book in which certain quantitative details pertaining to the cotton cloth and raw cotton have been certified. However, apparently this Certificate was neither before the Assessing officer and nor before the Ld. CIT(A) and the assessee has filed it in the pa....