2025 (4) TMI 1264

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....after, the Act] for the assessment year 2018-19. 2. The assessee has raised the following grounds in appeal: 1. That the Ld. national Faceless Appeal Centre [Ld. CIT (A) erred on facts and in law in sustaining the arbitrary and incorrect addition made by the Additional/ Joint/ Deputy/ Assistant Commissioner of Income Tax Officer National e- Assessment, Delhi [Ld. AO] 2. The Ld. CIT(A)/ Ld.AO erred on fact and in law in disallowing expenses under and section 37 of the income tax act 1961 ("the ACT") amounting to INR 49,48,880/- incorrectly alleging discrepancy in invoice furnished by the Appellant. 2.1 The Ld. CIT(A)/ Ld.AO failed to appreciate that the invoices completely matched with the ledgers furnished by the appellant and thus t....

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....y or withdraw any ground of appeal before or during the appellate proceedings. 3. The brief facts of the case are that the company is engaged in the business of construction, maintenance, improvement and development of civil and constructional works related to buildings, godowns, parks, hotels, bridges etc. The assessee filed its return of income on 30-09-2019 declaring total income at Rs. 60,340/-. The case of the assessee company was selected for complete scrutiny under the E-assessment on the following issues: (i) Expenses Relating to entities not Registered under GST Notices u/s 143(2) of the Act was issued. Again, notices u/s 142(1) of the Act was issued. In the compliance of the notice the assessee company filed the reply. The Asse....

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....able on record. 7. The ld. AR of the assessee as has relied on the following decisions: (i) CIT Vs. SVE engineers, appeal No. 350/2016 Hon'ble Madras High Court order dated 07-09-2016 (ii) CIT vs Nangalia Fabric Private Ltd (2014) 220 Taxmann. 17 in this case Hon'ble Gujarat High Court held that in case where purchases were supported by bills entries made in the books of accounts and payment was made by cheques, said purchases could not be held bogus purchase. (iii) CIT vs Smt. Anju Jindal [2016] 387 ITR 418 (Punjab & Haryana) (iv) Ramesh Kumar &Co, Ville Parle, vs. The ACIT. 8. In the present case in hand the assessee has submitted the expenses bills before the Ld. CIT(A) and AO. The expense bills payments were made through the b....