TaxTMI 
TaxTMI 
2025 (12) TMI 338
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....eless Appeal Centre (NFAC), Delhi [CIT(A)] dated 25-06-2024 in the matter of an assessment framed by Ld. Assessing Officer [AO] u/s. 147 r.w.s. 144B of the Act on 30-05-2023. The sole issue that arises for our consideration is addition of Rs. 316.58 Lacs as made by Ld. AO on account of alleged bogus purchases. The registry has noted delay of 42 days in assessee's appeal, the condonation of which has been sought by Ld. AR on the strength of condonation petition which is accompanied by an affidavit of accountant of assessee entity. Considering the fact that delay is a small delay, we condone the same and proceed for adjudication of the same on merits. 2. The Ld. AR advanced vehement arguments assailing impugned additions and referred to fi....
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.... furnished financial statements and copies of bills etc. However, going by the statement of Shri Avinash Chander, the amount of Rs. 316.58 Lacs was added to the income of the assessee and the assessment was framed. Appellate Proceedings 4.1 The assessee field detailed written submission to assail the stand of Ld. AO. The assessee pointed out that assessee's books of account were duly audited. The details of creditors, sales, debtors and quantitative stock details were duly verified in scrutiny proceedings u/s 143(3) and full disclosure was made by the assessee. The assessee furnished purchase bills with goods carriage receipt evidencing delivery of goods. The bills duly reflect quantity purchased, rate, details of goods carriage, truc....
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....was pointed out in the same. The assessee also drew attention to the fact that an assessment was framed by VAT authorities for this year accepting the sale and purchases as declared by the assessee. Accordingly, the assessee made out a case that the impugned purchases were genuine and no disallowance could be made in the hands of the assessee in terms of various judicial decisions. 4.3 The assessee also tabulated that the Gross Profit (GP) rate in this year was 6.71% which was better than GP rate of 5.31% in immediately preceding year. Similarly, the Net Profit (NP) rate of 0.27% as reflected in this year was much better than NP rate of 0.20% in immediately preceding year. 4.4 In the backdrop of factual matrix as put forth by the asse....
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.... volume of business, the assessee is required to maintain proper books of accounts. The assessee has maintained proper books of account as well as quantitative details of trading stock. The books have duly been audited under statute. The assessee was subjected to scrutiny u/s 143(3) on 16-12-2016 wherein the trading results were accepted and no discrepancy was found out in the sales, purchase or stock details. The assessee's trading goods are subjected to VAT and all sales and purchase are duly been reflected in the VAT returns. In fact, an assessment has been framed against the assessee for this year by VAT authorities for this year accepting the sale and purchases of the assessee. The assessee has furnished confirmed ledger account of M/s....