TaxTMI 
TaxTMI 
2025 (10) TMI 1337
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....s. 147 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act'). 2. The brief facts of the case are that the assessee had filed its return of income for the A.Y. 2014-15 on 29.11.2014 declaring total income of Rs. 25,93,822/-. Subsequently, the case of the assessee was reopened on the basis of information received that the assessee had made transactions with an accommodation entry provider in respect of purchases of Rs. 92,20,100/- Accordingly, a notice under Section 148 of the Act was issued on 22.03.2019. In the course of assessment, the Assessing Officer made addition of Rs. 92,20,100/- on account of purchases made from M/s. Siddh Syndicate which were held as bogus. The assessment was completed under Section 143(3) read with....
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....f the assessee was reopened on the basis of statement of one Shri Mahendra Shantilal Patel who had given statement that he was engaged in the activities of providing accommodational entries. The Ld. AR submitted that the assessee was not provided with the statement of Shri Mahendra Shantilal Patel and no opportunity to cross examine him was provided in spite of specific request. On the other hand, the assessee had furnished all the relevant evidences in the form of purchase bills, copy of ledger account, bank statement etc. to establish that the purchase of Rs. 92,20,100/- made by the assessee from M/s. Siddh Syndicate was genuine. The Ld. AR further submitted that the assessee had also co-related the purchases made from the said party with....
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....tation to parties, labour charges paid etc. The Ld. Sr. DR submitted that there was no dispute to the fact that M/s. Siddh Syndicate, from whom the assessee had made purchases of Rs. 92,20,100/- during the year, was operated by Shri Mahendra Shantilal Patel and this concern was providing entries in the nature of accommodation entry only. The Ld. Sr. DR further submitted that the assessee was unable to produce delivery documents such as delivery challans, vehicle numbers, weighing slips, bilty for transportation of goods etc. in respect of the purchases made from M/s. Siddh Syndicate; which substantiated the statement of Shri Mahendra Shantilal Paltel that the purchases made by the assessee from this party was bogus. The Ld. Sr. DR, therefor....
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.... Assessing Officer had made addition of Rs. 92,20,100/- based only on third party information and the transaction of the assessee was not subjected to any further scrutiny. The Assessing Officer also did not provide the copy of the statement of the accommodation entry provider to the assessee. 8.1 The assessee had co-related the purchases made from M/s. Siddh Syndicate with sales and reconciliation chart in this respect was brought on record in the paper-book filed by the assessee. The Revenue has neither disputed the sales shown by the assessee nor contradicted the reconciliation of purchases from M/s. Siddh Syndicate with corresponding sales. Considering the fact that the sales of the assessee has not been doubted, one can only conclud....