2025 (6) TMI 1466

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....d with section 144B of the Act for assessment year 2014-15 2. Brief facts of case are that assessee filed return of income for assessment year 2014-15 declaring total income of Rs. 3,11,080/-. As per information received from ITO, Investigation, Raipur and from insight portal, it was noticed that assessee made bogus purchases of Rs. 1,80,50,000/- with M/s. Shri Kapil Kumar Jain, proprietor of M/s. Shri Vaishno Devi Exim. Action under Section 147 of the Act was initiated against assessee after recording reasons and with prior approval from competent authority. Notice under Section 148 of the Act dated 31.03.2021 was issued to the assessee. In response to notice under Section 148 of the Act, assessee filed his return of income of Rs. 3,37,15....

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....r admitted that different purchase parties used to deposit amounts in the said bank account showing bogus purchases and Shri Kapil Kumar Jain used to either withdrawn the cash from his account or transfer the amounts to other concerns, which were generally also bogus. Shri Kapil Kumar Jain returned the cash to those purchase parties as stated by him. Shri Kapil Kumar Jain also admitted that he used to receive commission in cash from such purchase parties for the transactions routed through his bank account." Therefore, transactions to the tune of Rs. 1,80,50,000/ is out of books and remains unexplained undisclosed income for A.Y. 2014-15 and proposed to be added back in the total income of the assessee under Section 69A of the Act." 7. Ld.....