2025 (6) TMI 1380

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....l in the name of his proprietorship concern M/s. Maruti Petroleum. The assessee had filed his return of income for the A.Y. 2017-18 on 30.10.2017 declaring total income of Rs. 4,31,560/-. The case was selected for complete scrutiny under CASS. In the course of assessment, the Assessing Officer found that the assessee had shown purchase of Rs. 1,72,65,411/- which was made from M/s. Essar Oil Limited. The Assessing Officer had made enquiry from M/s. Essar Oil Limited by issue of notice under Section 133(6) of the Income Tax Act, 1961 (hereinafter 'the Act') and M/s. Essar Oil Limited had confirmed sales of Rs. 2,25,22,926/- to the assessee. Thus, there was difference of Rs. 52,57,515/- in the purchases as disclosed by the assessee. Since the ....

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....and illegal. It is so held now and the same be quashed. 4. Direction to charge interest under Section 234B and 234C without application of mind is unjustified. It is so held now. 5. The Appellant craves to add alter or amend the grounds of Appeal on or before the final hearing of the Appeal." 5. Shri Tej Shah, Ld. AR of the assessee submitted that the difference of Rs. 52,57,515/- in the purchase account was duly explained before the Ld. CIT(A) vide online submission made on 29.01.2021. He explained that the assessee had prepared Profit & Loss Account without considering VAT component in purchases and sales and that the difference of Rs. 52,57,515/- was on account of VAT which was directly taken to Balance Sheet. In support thereof,....