2025 (3) TMI 1087

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.... regard to the facts and circumstances of the case, the Ld. A.O has erred in issuing the final assessment order dated 23/12/2019, U/s 143(3)/147 of the Income Tax Act, 1961 without quoting the mandatory Documentation identification number ('DIN') in conformity with Para-2 and Para-3 of CBDT Circular No. 19/2019 dated 14th August 2019 and thus, the said final assessment order deserves to be held as invalid, bad in law and void-ab-initio. Reliance is placed on the following judgments: i. The Commissioner of Income Tax Vs Brandix Mauritius Holdings Ltd dated 30.05.2023. [149 taxmann.com 238 (Delhi)( HC)] ii. Jammat-E-Islami Hind, New Delhi Vs CIT (Exemptions), New Delhi dated 20.11.2023. [ITA No. 1289/Del/2023] iii. ....

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....cer has treated the purchase of Rs. 31,02,845/- as bogus purchases and without disputing or doubting the sales made during the year. He submitted that Assessing Officer has estimated 10% of the purchases as gross income of the assessee and the same was sustained by Ld. CIT(A). He submitted that the addition proposed by the Ld. Authorities are on higher side and assessee has declared net income of Rs. 3.5% of the total sales and he prayed that proper income may be estimated. 3. With regard to other additions made by the Assessing Officer of Rs. 6 lakhs u/s 68 of the Act he submitted that the Assessing Officer has merely observed that Rs. 3 lakh each of amount received from Goyal Trading Company and Sagar Enterprises (supra) as cash deposi....