2025 (12) TMI 858

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....hort) for Assessment Year 2018-19. 2. The assessee has raised following grounds of appeal:- "1.1 The order passed by u/s. 250 passed on 20.01.2025 for AY 2018-19 by NFAC [CIT(A)], Delhi (for short "CIT(A)") upholding the addition of Rs 25,00,059/- made by A.O. towards purchases from Kirit D. Patel, as bogus is wholly illegal, unlawful and against the principles of natural justice. 2.1 The ld. CIT(A), has grievously erred in law and or on facts in not considering fully and properly the submissions made and evidence produced by the appellant. The CIT(A) has passed a non-speaking order, relying upon the findings of AO which is illegal and unlawful. 3.1 The ld. CIT(A) has grievously erred in law and or on facts in ....

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....assessment was initiated merely on the basis of suspicion, without any tangible material linking the alleged bogus nature of transaction with Shri Kirit D. Patel to the assessee's books of accounts. The Ld. AR submitted that the assessee had disclosed the transaction in its books of accounts and reported it in audited financials. The Ld. AR further submitted that the transaction with Bhavani Enterprise, i.e. proprietorship concern of Shri Kirit D. Patel, was for sale of goods, duly recorded in sales register, and all payments were received through banking channels. Relevant documents such as invoices, delivery challans, stock records, and bank statements were furnished. On legal grounds, it was argued that there was no "information suggesti....

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....ctive from 01.04.2021. On going through the various information received from Insight Portal (High Risk CRIU/VRU cases dissemination of cases with priority mark as P1 category) and soft copy data downloaded by this office, inquiries conducted on said transaction, it appears that the transaction carried out by you has escaped assessment for AY 2018-19 within the meaning of section 147 of the IT Act." The Ld. AR also submitted that the issue in question had already been verified during the original assessment proceedings, and thus, the reopening amounted to a mere change of opinion, which is not permissible under law. 7. The Ld. DR, on the other hand, supported the orders of the authorities below. 8. We have heard the rival contentio....