TaxTMI 
TaxTMI 
2024 (6) TMI 820
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....-14 & 2014-15 respectively. 2. These two appeals are interconnected having common issues. Both these appeals are heard together and disposed off by this common order. We are taking ITA No.16/Del/2024 as a lead case. 3. Brief facts of the case are, the assessee filed its return of income for Assessment Year 2013-14 on 12th September, 2013 declaring total income of Rs. 2,96,45/-. The case of the assessee was reopened by issue of notice u/s 148 of the Income Tax Act, 1961 ('the Act' for short). On the basis of information and belief that assessee had failed to disclose the full and true material facts in respect of purchase from M/s Apex Associates through fake purchase bills issued by Shri Pritam Singh and Sh. Ajay Kumar, were engaged i....
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...., he sustained the addition made by the Assessing Officer. 7. Aggrieved with the above order, the assessee is in appeal before us raising the following grounds of appeal:- "1. On the facts and circumstances of the case, the order passed by the learned Commissioner of Income Tax (Appeals) [CIT(A)]. Income Tax Department (ITD), National Faceless Appeal Centre is bad, both in the eyes of law and on facts. 2 On the facts and circumstances of the case, learned CIT(A), ITD has erred both on facts and in law in confirming the order of the AO, without providing the assessee reasonable opportunity of being heard in clear violation of the principle of natural justice. 3 On the facts and circumstances of the case, learned....
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....ed. 7. (i) On the facts and circumstances of the case, the learned CIT(A), ITD has erred both on facts and in law in confirming the action of the AO despite the fact that the assessment order is invalid and liable to be quashed as the same has been passed by the AO without issue of valid notice under section 143(2) of the Income Tax Act. (ii) That the abovesaid notice issued under section 143(2) of the Act by the AO is illegal and non-est as the same has been issued in violation of section 148 r.w.s. section 151A of the Act along with e-Assessment of Income Escaping Assessment Scheme, 2022. 6. (i) On the facts and circumstances of the case, the learned CIT(A), ITD has erred both on facts and in law in confirming t....
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....act that the same has been made by the AO by indulging in surmises without bringing on any direct evidence against the assessee, only on the basis of presumptions and assumptions. 12. On the facts and circumstances of the case, the learned CIT(A), ITD has erred, both on facts and in law in confirming the above disallowance rejecting the contention of the assessee that said disallowance has been made merely relying on the information received from the investigation wing without independent application of his own mind. 13. On the facts and circumstances of the case, the learned CIT(A), ITD has erred, both on facts and in law in confirming the above disallowance in drawing adverse inference, by misinterpreting the statement r....
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.... appeal filed by the assessee for Assessment Year 2014-15, he submitted that the additions made by the Assessing Officer which is exactly similar reasons and AO has disallowed the purchases made by the assessee from Apex Associates without properly making enquiry. He submitted that AO has made the addition of Rs. 4,85,000/- as non genuine purchase, however, he brought to our notice ledger copy of the Apex Associates which is placed at page 46 of the PB wherein assessee has not purchased any material from Apex Associates during this assessment year, however, assessee had only made payment towards the outstanding balance towards the purchase of earlier years, therefore, AO cannot disallow the same during this year. He submitted that the Asses....