2024 (7) TMI 1225

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....reinafter referred to as the "Act"), dated 17.03.2016 for Assessment Year 2011-12. 2. Grounds taken by the assessee are reproduced as under: "1. (a) On facts and circumstances of the case and in law, Ld. CIT(A) erred in dismissing the appeal and sustaining the addition as it is a proven fact by various judicial authorities that sales without purchases is not possible for a trader. (b) The CIT (A) erred in sustaining to 25% addition without appreciating the understated vital facts that the purchases are duly supported with necessary documentary evidences including quantitative tally of purchases and sales and there appears no sign of it being bogus and the learned officer has not given a fair opportunity of putting forward the facts. ....

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....iefly stated facts are that assessee filed his return of income on 16.08.2011 reporting total income at Rs. 4,90,648/-. Case of the assessee was re-opened u/s. 147 by issuing notice u/s. 148 on 05.11.2014 after receipt of information from DGIT (Inv) Wing, Mumbai, that assessee is a beneficiary for hawala purchase entries from 12 different parties totalling to Rs. 2,15,88,627/-. The ld. Assessing Officer asked the assessee to furnish supporting documents for purchases made from the 12 parties along with supporting documents for corresponding sales affected by the assessee. Assessee furnished certain details in compliance to the notices issued by the ld. Assessing Officer. Ld. Assessing Officer concluded that it is only the profit embedded in....