2024 (8) TMI 869

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.... 2. Therefore, the assessee is aggrieved with the same has preferred this appeal raising several grounds. 3. The fact of the case shows that the assessee is an individual where he filed his return of income declaring total income of Rs. 164,870 as he is dealing as a trader in Farah's and nonferrous metal. The name of the assessee appears as a beneficiary in obtaining accommodation entries and hawala bills from non-existing entity is discovered by Maharashtra sales tax department and information passed on to the assessing officer by the director general of income tax, investigation Wing, Mumbai that assessee has made purchases of Rs. 3,620,179/-from one party namely Sai Kripa metallic traders. Therefore, the notice under section 148 was....

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....ve vehemently submitted that assessee has been provided enough opportunities before the lower authorities, assessee did not avail of these opportunities therefore the claim of the learned authorized representative that the proper opportunities before the learned AO and the learned CIT appeal is not given is absolutely false. On the issue of reopening of the assessment it was submitted that there is a tangible material in the form of information received that assessee has obtained the bogus invoices from one party. The assessee failed to prove the genuineness of such purchases; several details were asked of them were filed before the learned assessing officer therefore it shows that the reasons recorded by the learned assessing officer are c....