TaxTMI 
TaxTMI 
2025 (5) TMI 1852
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....it was filed. It was stated in the condonation petition that there was change of management in the assessee company during the F.Y. 2018 and new directors took over and old directors resigned. It was further stated that as per the terms agreed upon between the director's, the old management of the company would be liable for the liabilities arising prior to the change of management and therefore, would responsible for the assessment, reassessment proceedings related to A.Y. 2011-12. It was also stated in the assessment order passed u/s 143(3) of the Act by ITO, Ward 3(3), Kolkata on 17.12.2018 that the old management appointed a consultant, who filed the appeal before the ld. CIT(A) alongwith written submission with digital signature of Mr.....
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....tion of addition of Rs. 42,24,191/- by the ld. CIT(A) as made by the ld. AO on account of bogus purchases u/s 69C of the Act as unexplained expenditure in the hands of the assessee company. 06. The facts in brief are that the assessee filed the return of income on 30.09.2011, declaring total income of Rs. 9,78,204/-, which was processed u/s 143(1) of the Act. Subsequently, a search action u/s 132(1) of the Act was conducted on Shri Sanjiw Kumar Singh, who was an entry operator and his related entities. During the course of search, Mr. Singh admitted that he was engaged in providing accommodation entries in the form of bogus purchases on commission basis. The information received by the ld. AO that M/s Dhar & Company Pvt. Ltd., the assessee....
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.... course of search of Shri Sanjiw Kumar Singh and his associated concerns. The assessee complied with the said notices and produced the evidences /details such as bills and vouchers and stock registers etc. The accounts of the assessee were also duly audited and the auditor has not drawn any adverse inference in respect of the said purchases. Moreover, the ld. AO has not disbelieved the sales made by the assessee out of the said purchases. We note that during the year the gross profit declared by the assessee was 20.09%, whereas the net profit was 2.71%. In such above scenario the only presumption is that the purchases were made from the grey market whereas the bills were procured from hawala entry operators. Since, the assessee has already ....