2025 (9) TMI 521

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....mit Kumar Soni, Charki Dadri, Haryana during FY 2010-11. He observed that assessee has provided accommodation entries of Rs. 6,77,320/- in its bank account through a party, M/s. Shri Radha Krishan Traders. With the above reasons and after taking approval under section 151 of the Income-tax Act, 1961 (for short 'the Act'), notice was issued u/s 148 of the Act dated 27.03.2018 and duly served on the assessee. In response, assessee filed his return of income for AY 2011-12 declaring total income of Rs. 7,17,900/-. Notices u/s 143(2) and 142(1) were issued and served on the assessee. The AO observed that during the year under consideration, assessee has declared turnover of Rs. 10,06,00,309/- from the trading of edible oil. In response, ld. AR ....

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.... (A) and filed detailed submissions before the ld. CIT (A) which is reproduced at pages 4 to 10 of the impugned order. After considering the above, ld. JCIT (A) sustained the addition made by the AO with the following observations :- "6.3 During this proceeding, the appellant has submitted whole transaction of Rs. 6,77,320/- recorded in the regular books of account of the assessee and the said payment was received against the sales of edible oils previous year and said sales included in the total sales of previous year and the amount of Rs. 6,77,320/- was outstanding as a debtor in the books of assessee in the schedule of debtors audited balance sheet as at 31.03.2010. The said payment received through RTGS on 01.09.2010 during the....

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....goods through the carrier Rekhi Speedways and submitted that the details of product also were submitted before the lower authorities. He prayed that this is a genuine transaction which is completed in Assessment Year 2010-11. The AO cannot treat the same as bogus and assessee has received the payment only in AY 2011-12. 6. On the other hand, ld. DR of the Revenue brought to our notice page 3 of the assessment order wherein AO has proceeded to treat the transaction as accommodation entry based on the specific statement from Vipin Garg. The assessee was given several opportunities by the AO but assessee has not filed any cogent material before him 7. In the rejoinder, ld. AR of the assessee submitted that lower authorities have given wr....