2025 (9) TMI 235

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....nder:- "1. That the order passed by the Ld. CIT(A) u/s 250(6) of the Income Tax Act, 1961 (herein referred as 'the Act') is incorrect, bad in law and have been passed without appreciating the submissions made in the facts and circumstances of the present case. 2. That the Ld. CIT (A) has grossly erred while upholding the assessment order passed by Ld. Assessing Officer ('AO') u/s 147 r.w.s of 144B of the Income Tax, 1961 which is incorrect, bad in law and have been passed without considering the submission of the Assessee. 3. That the initiation of reassessment proceeding in the present case by way of SCN /s 148A(b) of the Act is wrong in absence of any escapement of income and subsequent notice u/s 148 of the Act....

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....nded to the summons issued u/s 133(6) of the Act by the Ld. AO of PAN Group establishing the genuineness and Ld. CIT(A) has erred in upholding the same. 8. That the Ld. CIT (A) has grossly erred while upholding the order of Ld. Assessing Officer treating the income as unexplained credit in the books of the Assessee u/ s 68 r.w.s I5BBE of the Act, without perusal of documents and evidence produced during hearing. 9. That the Ld. CIT (A) has grossly erred in upholding the initiation of penalty proceedings by Ld. Assessing Officer u/s 271AAC of the Act. 10.That the Ld. CIT (A) has grossly erred in upholding the charging of interest by Ld. Assessing Officer u/s 234A, 234B, 234C & 234D of the Act." 3. Brief facts of the case....

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.... before the Ld. CIT(A). The Ld. CIT(A) vide order dated 14/06/2024, dismissed the Appeal filed by the Assessee. As against the order of the Ld. CIT(A), the Assessee preferred the present Appeal on the grounds mentioned above. 5. The Ld. Counsel for the Assessee submitted that the A.O. in the case of Pan Group search cases made the allegation of bogus purchases from certain suppliers including the Assessee herein to the tune of Rs. 53,33,856/- and the addition was also made in the hands of Parmanand and Sons food Pvt. Ltd. The Ld. Counsel further submitted that the Co-ordinate Bench of the Tribunal in the case of Parmanand and Sons food Pvt. Ltd. in ITA No. 980/Del/2022, held that certain parties including the Assessee had in-fact replied....