2025 (6) TMI 1696

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.... of the Income Tax Act, 1961 (hereinafter referred to as the "Act") and relates to Assessment Year (A.Y.) 2021-22. 2. The grounds raised by the assessee are as under: "1. The learned Commissioner of Income Tax (Appeals) [CIT(A)] erred in confirming the addition of Rs. 5,21,27,915/- by treating the entire purchases as non-genuine and alleging the same as unaccounted money. The addition is based on conjectures and surmises, without properly considering the appellant's submissions, supporting evidence, and confirmations." 2. The order is in violation of the principles of natural justice, as adequate opportunity was not granted to the appellant to rebut the findings of the Assessing Officer (AO) or cross-examine the par....

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....ly preceding year. The case of the assessee was selected for scrutiny and during assessment proceedings the assessment unit observed that the assessee had made purchase of Rs. 5,21,42,915/- only from three parties i.e. M/s. Arihant Jewellers Prop: Shri Hardik Rasiklal Shah Rs. 2,17,66,264/-, M/s. Viram jewelers Prop: Shri Vishal Ganeshbhai Adesara Rs. 3,03,61,651/- & M/s. Bap Fibres Prop: Jayvin Amrutlal Patel Rs. 15,000/-. To ascertain the genuineness of the transaction of purchases notices u/s.133(6) of the Act were issued to three parties, out of which, only one i.e. Jayvin Amrutlal Patel, Proprietor of M/s. Bap Fibres confirmed his transaction with the assessee, though, he stated to have sold only cloths to the assessee. Accordingly, th....

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.... genuineness of the purchases made by it. He further pointed out that the assessment unit relied on the investigation report of proprietor of M/s. Viram jewelers i.e. Shri Vishal Ganeshbhai Adesara and on the purchases made by the assessee from the same. Likewise, he pointed out that even the sales made by the assessee were found to be not genuine to the tune of Rs. 4,29,52,810/- based on an enquiry carried out by the assessment unit by issuing notice to the parties to whom sales were made more, particularly, M/s. Meet Jewels to whom sales of Rs. 4.19 Crore was made and the transaction with whom was found to be suspicious. Ld. Counsel for the assessee contended that none of this adverse information was confronted to the assessee by assessme....