2024 (12) TMI 1568

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.... D.R ORDER PER : NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER: This appeal has been preferred by the Assessee against the order dated 06.03.2024, impugned herein, passed by the National Faceless Appeal Center (NFAC)/Ld. Commissioner of Income Tax (Appeals) (in short Ld. Commissioner) under section 250 of the Income Tax Act, 1961 (in short 'the Act') for the A.Y. 2011-12. 2. In the instant ....

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....nt order dated 28.11.2016 u/s 144 r.w.s. 147 of the Act. 3. The Assessee, being aggrieved, challenged the said addition before the Ld. Commissioner, but could not succeed as the Ld. Commissioner by considering the conclusion drawn by the AO in making the addition, as well as claim/reply of the Assessee, ultimately affirmed the aforesaid addition, by observing and holding as under: "Gro....

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....der is a cryptic order and the Ld. Commissioner has not considered the factual aspects in its right perspective. Even otherwise, from the conclusion drawn, it appears that the Ld. Commissioner has recorded that there are no evidences for bogus sales and therefore according to the Ld. Counsel the impugned order is liable to be set aside. The Ld. Counsel further stated that without prejudice to the ....

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....ee before the AO as well as before the Ld. Commissioner except filing the reply has not produced proper documents to establish genuineness of the purchases made, and therefore the same has been considered as bogus by the authorities below and thus on this aspect no interference is warranted. However, coming to the second/alternate claim raised by the Ld. Counsel on behalf of the Assessee, this Cou....