2025 (2) TMI 1211

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....reinafter referred as 'the Act']. 2. The Assessing Officer in his assessment order has discussed the addition made as follows: "The assessee company has filed the return of income on 17.09.2014 declaring loss of Rs. 4,05,19,529/ -. The return was processed u/s 143(1). Case was selected for scrutiny through CASS. Accordingly, statutory notice u/s 143(2) dated 18.09.2015 was issued by DCIT, Central Circle-27(1), New Delhi and duly served on the assessee. Subsequently statutory notice u/s 143(2) and 142(1) dated 30.08.2016 was issued by DCIT, Central Circle-II, Faridabad upon change of jurisdiction and duly served on the assessee. In compliance to the said notices, Shri K.C. Garg, AR on behalf of the assessee attended the assessment....

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....at the appellant company belongs to SRS Group, where the investigation after search shows that the companies of the group are floated to show bogus, purchase and sale within the group without any actual transaction. The expenditure on freight and cartage is also thus shown only to inflate expenses without there being actual business. The observations of the AO appear to be correct. It is noticed from the documents submitted before me that the appellant is operating from a residential address at Faridabad. There are no godowns owned or taken on rent by the appellant. This means that there is no place where appellant can store or keep the voluminous buildings material and grocery items. It is also significant to note that the appellant is s....

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....we find in the relevant financial year, the assessee has reported losses from operations of Rs.213 crores and in which the Revenue from sale of shares is around Rs. 13,11,00,000 while Revenue from sale of building material is over Rs. 200 crores. The nature of the business of the assessee certainly required to too much transport of the goods of the nature of building material. Learned counsel has relied on a letter made available on page nos. 64 and 65 of the paper books to submit that complete books of account/bills/vouchers along with bank statements were produced before the Assessing Officer for verification. We find that the learned Tax Authorities Below have not examined any of the financials and other evidences and merely on the basis....