TaxTMI 
TaxTMI 
2025 (5) TMI 345
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....any engaged in the business of manufacturing of agriculture equipment and trading of iron and steel. The return of income for the year under consideration was filed on 28/09/2012 declaring total income at Rs. 9,27,969/-. Originally, the assessment u/s 143(3) of the Income Tax Act, 1961 ('Act' for short) was completed in the case of the Assessee in terms of order passed on 25/02/2015, wherein the income declared by the Assessee was accepted with a minor adjustment of Rs. 19,253/- on account of disallowance of certain expenses.During the course of original assessment proceedings, the Assessee filed all the necessary details as called for from time to time with regard to the purchases, sales and inventory maintained by the Assessee on day to d....
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....ground of Appeal No. 9 & 10 and the Grounds of Appeal No. 1 to 8 are not pressed. Therefore, the Ground No. 1 to 8 of the Assessee are dismissed as not pressed. 6. In Ground of Appeal No. 9 & 10, the Assessee challenged the action of the Ld. CIT(A) in confirming the addition of Rs. 40,00,000/- made by the A.O. u/s 68 of the Act and Rs. 60,000/- u/s 69C of Act. The grounds of Appeal No. 9 & 10 are reproduced as under:- "9. (i) On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirming the addition of an amount of Rs. 40,00,000/- on account of sales receipts credited in the bank account treating the same as bogus invoking section 68 of the Income Tax Act. (ii) That the ....
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....of the same were also filed before the A.O. who after verifying all the details with reference to books of account and bills and vouchers produced, concluded that the trading stock declared by the Assessee are correct and no discrepancies were pointed out with respect to the maintenance of the books of accounts of the Assessee company. Once the necessary enquires have been made with regard to the sale, in the re-assessment proceedings, the A.O. alleged that the sales made to M/s Akshay Sales Corporation and M/s Multi Blizz Construction are not genuine and the amounts received as sale consideration is accommodation entry. 8. The Ld. Assessee's Representative submitted that the A.O. alleges that no details of books sold were mentioned ....
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....aking addition of the sales by holding the same as accommodation entry deserves to be upheld. Thus sought for dismissal of the Appeal. 10. We have heard both the parties and perused the material available on record. In the instance case, originally the assessment was completed u/s 143(3) of the Act, wherein all the details with respect to purchase and sales were filed by the Assessee and the same were examined by the then Assessing Officer. It is also pertinent to note that, stock records maintained by the Assessee Company on day to day basis were also examined by the A.O. and after such examination, the Ld. A.O. accepted the books of accounts. However, in reassessment proceedings despite of all the material available on record, the A.O.....