2025 (7) TMI 1850

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....pellant : Ms. Preyashi Tated, AR For the Respondent : Shri B.P. Makwana, Sr DR ORDER PER DR. B.R.R. KUMAR, VICE-PRESIDENT:- The captioned appeal has been filed by the assessee against the order dated 24.12.2025 passed by the Ld. ADDL/JCIT(A)-9, Mumbai (hereinafter referred to as "CIT(A)" for short), passed u/s 250 of the Income-tax Act, 1961, (hereinafter referred to as "the Act" for s....

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.... declaring income of Rs. 5,49,140/-. Subsequently, a revised return was filed declaring income of Rs. 5,03,910/-. The return was processed under Section 143(1) of the Act. Subsequently, based on information received from the Commercial Tax (Enforcement) Department, Ahmedabad, and the ITO (Investigation), Unit-1, Ahmedabad, it was noted that the assessee had allegedly suppressed purchases and sales....

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....sessing Officer, the assessee filed an appeal before the Ld. CIT(A), who affirmed the action of the AO determining 2% on the transactions. Aggrieved by the order of the Ld. CIT(A), the assessee is now in appeal before the Tribunal. 5. Before us, the Ld. AR contended that the Assessing Officer made an arbitrary and excessive addition without any direct evidence or verification and merely on esti....

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.... material available on record. The core issue is the estimation of income based on alleged bogus transactions without proper inquiry or opportunity of cross-examination. We find from the record that the reopening is solely based on third-party information without any independent verification. It is also a fact on record that the Assessing Officer neither summoned nor cross-examined the officers wh....