2025 (10) TMI 1104

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.... the following grounds of appeal: 1. The Assessing Unit has erred on the fact and in Law treating Actual / Real transaction of Sales of Gold Bar as accommodation Bill, Undisclosed income and making addition to total Income u/s 69A of the Income Tax Act, 1961. 2. The Assessing Unit has erred on the fact and in law not treating Actual / Real transaction of Sale of Gold Bar just for want of confirmation to enquiry u/s 133(6) of the Act from customer Viko Enterprise. 3. In spite of providing all the required legitimate evidences of sales transaction with Viko Enterprise and not finding any incriminate documents against the assessees, the transaction is treated as accommodation entry. Just relying on the basis of infor....

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....peal before the Ld. CIT(A), who dismissed the appeal of the assessee by observing as follows: "...6. Decision: I have considered the facts of the case, written submission and case laws relied upon by the appellant as against the observations and findings of the AO in the assessment order. The submissions and contentions of the appellant are discussed and decided as under: 6.1 Ground No.1: In this ground the appellant has challenged the addition worth Rs. 11,27.000/- u/s. 69A of the Income Tax Act. 1961. The information was received from the Investigation wing that the appellant has taken accommodation entry worth Rs. 11.27.000/- The appellant replied to the AO that he has sold gold bar to Mis Vico Enterprises The AO issued....

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....order of the Ld. CIT(A), the assessee is now in appeal before the Tribunal. 6. The Ld. Counsel for the assessee submitted that the assessee had sold gold weighing 350 grams to M/s. Vico Enterprise, having address at 86, Bhagwandas ni Chali, Khokhara, Mehmedabad, Ahmedabad, vide Bill No. 1/4 dated 15.11.2016. The gold was sold at the rate of Rs. 3,188.12 per gram, amounting to Rs. 11,15,842/-. During that period, service tax was applicable, and therefore, 1% service tax amounting to Rs. 11,158/- was charged, aggregating to a total sale consideration of Rs. 11,27,000/-. The assessee furnished all relevant documents substantiating the genuineness of the transaction, including: * Sales Invoice * Bank Statement * Le....