2025 (4) TMI 1649

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....he assessee submits that the case of assessee was reopened u/s.  148 of the Act to examine alleged accommodation entry aggregating to Rs. 1,94,00,000/- taken by assessee from M/s. Parth International, Prop. Shri Anuj Kumar Gupta. During assessment proceedings u/s.  147 r.w.s. 148 of the Act, the Assessing Officer (AO) had issued notice u/s.  142(1) of the Act dated 22.02.2022 along with questionnaire making specific enquiries with regard to receipts of Rs. 1,94,00,000/- from M/s. Parth International. The assessee furnish detailed reply to the said notice on 10.03.2022. The Assessing Officer after being satisfied with the reply furnished by the assessee, made no addition in the assessment order. Thereafter, the PCIT ....

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....ntra, Ms. Harpreet Kaur Hansra representing the department vehemently defended the impugned order and prayed for dismissing appeal of the assessee. The ld. DR pointed that a perusal of the assessment order dated 29.03.2022 would show that the AO vide notice u/s.  142(1) dated 20.12.2021 had requisitioned various documents from the assessee. The assessee furnished partial information. Since, the assessment was approaching time-barring period, the AO completed the assessment admitting the returned income. The assessment order has been passed without proper enquiries and is a fit case for PCIT to exercise revisional jurisdiction u/s.  263 of the Act. 4. Both sides heard, orders of the authorities below examined. Undisputedly, the ca....

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....r FY 2012-13 Copy of assessment order for FY 2012-13. 5. Copy of bank statement of M/s Sheeba International for FY 2012-13. 6. That the copy of ledger account of M/s Parth International in the books of the assessee for FY 2012-13 has already been submitted in para 1 above. 5. However, no documentary evidence was furnished by the assessee to substantiate that the reply dated 10.03.2022, along with documents mentioned in the said reply were uploaded/furnished by the assessee before the AO. Here, it would be relevant to mention that the AO in the assessment order dated 29.03.2022, has categorically observed that the assessment is being completed in the absence of complete documents, the assessee has not uploaded complete books of account ....