TaxTMI 
TaxTMI 
2025 (9) TMI 36
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....sh Kumar Bagri ITO, Ward-2(1), Faridabad CIT(A)/NFAC, Delhi's order dated 28.08.2024 having DIN & Order No. ITBA/NFAC/S/250/2024-25/1068073741(1) involving proceedings under Section 147 r.w.s. 144 of the Act. 2. 42/Del/2025 for AY: 2014-15 Sh. Ramesh Kumar Bagri ITO, Ward-2(1), Faridabad CIT(A)/NFAC, Delhi's order dated 29.08.2024 having DIN & Order No. ITBA/NFAC/S/250/2024-25/1068124334(1) involving proceedings under Section 147 r.w.s. 144 of the Act. 3. 43/Del/2025 for AY: 2015-16 Sh. Ramesh Kumar Bagri ITO, Ward-2(1), Faridabad CIT(A)/NFAC, Delhi's order dated 29.08.2024 having DIN & Order No. ITBA/NFAC/S/250/2024-25/1068124993(1) involving proceedings under Section 147 r.w.s. 144 of the Act. 4. ....
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....cts, a perusal of the assessment order dated 24th March, 2022 reveals that the Assessing Officer had proceeded in section 147 r.w.s. 144 proceedings against the assessee for the purpose of assessing his entire credits of Rs. 55,17,27,091/- as unexplained for want of his explanation which has been partly extracted to 0.5% in the lower appellate discussion, reading as under: "1. 1. Ground nos.1 Ground number 1 is generic in nature and does not command a separate decision on the same 1. 1. Ground No. 2 Ground number 2 is the material ground which stems from the action of the AO in adding the credit entries appearing in assessee's books as he found them unsubstantiated, more so on account of the fact that....
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....es from the buyer, thus standing in absolute contrast to the stand of the assessee. 3. Another party, M/s Nikunj Udyog did not provide any details regarding the purchases effected from them except a copy of ledger, which as per the AO did not match with the books of the assessee. Pertinent be it to mention that no other details were submitted which could enhance the credibility of the transactions. 4. Regarding the sell side, Unitech Ltd acknowledged merely that they used to buy steel from the assessee but the ledger did not match with the one provided by the assessee. 5. The assessee claimed that it had received advance of Rs. 3,00,00,000 from M/s S.V.S Buildcon Private Ltd. The AO issued 133(6) during the remand....
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....ellant, the evidences adduced to his defense and the findings of the enquiry during the remand proceedings. The paucity of material documents amplify the conclusion that the assessee is in fact an entry provider. Even if one assumes that the documents were lost, it is inconceivable that the appellant did not have any access to other supporting documents like way bills, stock register, payment advice etc. The capital base of the assessee is indeed meagre when compared to the turnover. The bank accounts reflect the classic pattern of money and money out. Thus in view of the above the averments of the appellant as being a genuine enterprise do not hold much credence. Furthermore, there was a letter from the DDIT (Inv) Faridabad to the AO durin....
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.... 0.15 at the lowest to 0.8 at the highest. In general, the rates for loans carry higher rates and those for the bogus bills etc carry the lower rates. In view of the above, I believe that a rate of 0.5% of the turnover shall be a fair indicator of the appellant's income. The AO nis directed to estimate the income at 0.5% of the turnover. Thus the appeal of the assessee on ground no. 2 is partly allowed." 5. It is sufficiently clear that what all the assessee's accounts have witnessed is a continuous flow of credits and debits wherein he has been found to be a mere accommodation entry provider on account of his failure in filing the supportive evidence claiming any genuine business activity. We thus see no reason to interfere with the....