2025 (6) TMI 1474

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.... For the Revenue : Ms. Kavita P. Kaushik, Sr. D/R ORDER PER NARENDRA KUMAR BILLAIYA, AM: This appeal by the revenue is preferred against the order of the ld. CIT(A) - 48, Mumbai [hereinafter "the ld. CIT(A)"] dated 12/10/2022 pertaining to AY 2019-20. 2. The sum and substance of the grievance of the revenue is that the ld. CIT(A) erred in deleting the addition of Rs. 5,39,10,500/- u/s 69A of ....

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....ustomers based on his choice from the menu. Accordingly, the assessee's major business is done in cash. 6. It has been brought to the notice of the AO that the business had been transferred and is now being carried out in the name of M/s. Krishay Enterprises from 01/04/2018. During the course of survey action, the two bills were found in the name of Vividham Sweets, dated 24/10/2018 and 25/10/201....

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.... income at Rs. 5,39,10,500/-. 7. Before the ld. CIT(A), it was reiterated that Vividham Sweets is a brand and Vividham Sweets and Krishay Enterprises are two partnership firms and Vividham Sweets and Dry Frutis was dissolved on 31/03/2018 and the entire business was conducted by Krishay Enterprises from 01/04/2018. The sales summary of both the firms for AY 2018-19 was explained as under:- Asses....

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....d in these two bills are meagerly Rs. 25,467/- and Rs. 68,977/. The entire exercise done by the AO may impress a student of mathematics but does not make any sense so far as the income tax proceedings are concerned. No effort was taken to verify from the books of Krishay Enterprises. The month-wise details of sales made by two firms mentioned elsewhere speak for itself. As can be seen, Krishay Ent....