2025 (11) TMI 467

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....ed in both these appeals are identical, these appeals are taken up together for adjudication and are decided by this common order. 2. For the sake of convenience, the appeal of the assessee for AY 2013-14 is taken up as a lead case and the facts are narrated from the said appeal. 3. Shri Ajay Wadhwa, appearing on behalf of the assessee submits that the assessee is a trader, the assessee filed return of income for AY 2013-14 on 19.09.2013 declaring income of Rs. 3,67,410/-. Thereafter, notice u/s. 148 of the Income Tax Act,1961(hereinafter referred to as 'the Act') was issued to the assessee on 30.03.2019 and assessment u/s. 143(3) r.w.s. 147 of the Act was completed vide order dated 25.12.2019. The ld. Counsel submitted that the asses....

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....ed the addition on merits. 4. Per contra, Ms. Sudha Gupta representing the department vehemently defending the impugned order and prayed for dismissing appeal of the assessee. 5. Both sides heard, orders of the authorities below examined. The assessee has assailed reopening of assessment. A perusal of reasons recorded for reopening reveal that Revenue has alleged bogus purchases by the assessee from M/s Jai Shiv Enterprises a proprietorship concern of Shri Dilip Kumar. I find contradiction in the reasons recorded by the AO. As in the first part of the reasons it is alleged that the assessee has obtained accommodation entries from M/s. Jai Shiv Enterprises, however, in the later part of the reasons i.e. para 4 it has been alleged that ....