2022 (10) TMI 1218
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....14th August 2019 which provides for compulsory issue of a computer-generated Document Identification Number (DIN) and quoting of the same in the body of such communication, by any income-tax authority relating to assessment, appeals, orders, statutory or otherwise, exemptions, enquiry. investigation, verification of information, penalty, prosecution, rectification, approval etc. to the assessee or any other person, on or after the 1st day of October, 2019, failing which such communication shall be treated as invalid and shall be deemed to have never been issued 2. On the facts and in circumstances of case and in law, the Ld CIT(A) erred in estimating the profit from alleged Hawala purchases being Rs. 4,22,145/@ 12.50% of the allege....
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....s @1 2.50% from similar transactions. 6. On the facts and in circumstances of case and in law, the L.d. CIT(A) erred in by confirming an Ad Hoc addition of Rs 75,000/- on account of lower household withdrawal considering the status of the appellant and his standard in the society. 7. On the facts and in circumstances of case and in law, the Ld. CIT(A) erred by confirming an Ad Hoc addition of Rs 50,000/- on account of various expenses which were allegedly not fully verifiable 8. On the facts and in circumstances of case and in law, the Ld CIT(A) erred in not following the ratio of jurisdictional ITAT and the High Court, according to which only profit element embedded in the alleged bogus purchases can be taxed and....
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....A.O noticed that assessee had shown purchases made from hawala parties aggregating to Rs. 83,29,186/-. Out of these only one party i.e M/s Abhishek Enterprises complied with the notice issued u/s 133(6) and stated that he did not have any transaction with assessee and other 7 parties had not made compliance with the notices issued by the A.O. Therefore, the A.O asked the assessee to produce the parties before him to prove the genuineness of the transaction but the assessee failed to in doing so, therefore, the A.O had disallowed an amount of Rs. 80,08,830/- on account of bogus purchases. The A.O has further noticed that assessee had shown outstanding sundry creditors amounting to Rs. 78,53,348/-. The A.O had issued notices u/s 133(6) to ....
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....ished confirmation from these creditors in spite of being asked by the A.O during the course of assessment proceedings and therefore, addition of Rs. 64,17,345/- made by the A.O was confirmed in respect of such creditors. In respect of addition of Rs. 75,000/- and Rs. 50,000/- on account of household withdrawal and expense incurred in cash the assessee has not submitted any detail before the CIT(A), therefore, the ld. CIT(A) has confirmed such additions. 6. During the course of appellate proceedings before us neither the assessee has attended nor submitted any detail, therefore, after hearing the ld. D.R and after taking into consideration the material on record, we consider that in respect of bogus purchases the assessee had not produce....
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