2025 (10) TMI 569

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....ing addition of Rs. 2,43,081/- on the basis of difference in ledger balance of supplier (Konkan Agro Marine Pvt Ltd.) with the books of assessee. 2. Whether on the facts and in the circumstances of the case, the learned Assessing Officer was justified in making addition of Rs. 9,92,930/- on the basis of non-accounting of credit note issued by supplier (Konkan Agro Marine Pvt. Ltd.). 3. Whether on the facts and in the circumstances of the case, the learned Assessing Officer was justified in making addition of Rs. 5,45,061/- on the basis of difference in ledger balance of supplier (Royal Drinks) with the books of assessee. 4. Whether in fact and law of the case the Ld. CIT(A) is justified in passing an order in breach of principle of na....

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....ing the course of assessment proceedings the ledger accounts of some parties were called which are filed by the assessee. The assessee was asked to reconcile the accounts. The assessee filed the reconciliation. In the case of Konkan Agro Marine Ind. Pvt Ltd it was seen that the said party has shown opening balance at Rs 55,33,799/- whereas the assessee has shown the balance at Rs 57,76,880/-. Thus there Is difference in account of Rs 2,43,081/-. The said excess liability/unreconciled balance of Rs 2,43,081/- is income of the assessee & hence added to the income of the assessee......." 5. With regard to the addition on account of unaccounted credit notes, the Assessing Officer made addition of Rs. 9,92,930, by making following observations:....

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....:- "5.2.3 The A.O. has made addition on account of difference in account and not accounted for credit notes of Rs. 2,34,081/- and Rs. 9,92,930/- respectively. During the course of appeal proceedings, the appellant has furnished reconciliation sheet of the M/s Konkan Agro and copy of ledger account for the period from 01.04.2014 to 31.03.2015. However, the appellant has failed to furnish the ledger account for the period from 01.04.2013 to 31.03.2014 and reasons for difference in opening balance of Rs. 2,43,081/- and credit notes of Rs. 9,92,930/-. The appellant has accepted the accounting error and has stated that its effect along with effect due to some other erroneous entries has been offered for taxation in the amount of Rs 604,791/- o....

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....for the assessee, Smt. Veena Agrawal, appearing for the assessee assailing the impugned order passed by the learned CIT(A), submitted that the additions made by the Assessing Officer which were confirmed by the learned CIT(A) are bad in law as difference in the opening balance could not be added to the total income of the assessee for the year under consideration and the credit notes were settled in the subsequent assessment year and addition will lead to double taxation. 10. The learned Departmental Representative has not made any effective arguments to controvert the submissions made by the learned Counsel for the assessee and thus relied upon the orders of the authorities below. 11. I have heard the rival arguments, perused the materia....