TaxTMI 
TaxTMI 
2025 (12) TMI 1355
X X X X Extracts X X X X
X X X X Extracts X X X X
....r section 147 r.w.s. 144 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') relating to the Assessment Year 2020-21. 2. Brief facts of the case is that the assessee is a Cooperative Bank has not filed the Return of Income for the Asst. Year 2020-21. The assessee had made total sales as reported under GSTR-1 and GSTR-3B of Rs. 6,32,19,719/- and also made cash withdrawal amounting to Rs. 2,38,60,796/- from the Banaskantha District Central Co Op Bank Ltd. Therefore the assessment was reopened by issuing a notice u/s. 148 of the Act. The assessee filed the return on 15-02-2025 which is beyond 30 days time given to the assessee. The assessing officer called for details u/s. 133(6) from the banks and a final show cause notice d....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ear 2020-21 and demanded tax thereon. 3. Aggrieved against the assessment order, assessee filed an appeal before Ld. CIT(A), who considered the submissions of the assessee, however confirmed the order passed by the assessing officer by observing as follows: "7.1 At the very outset, it is important to note that in this case the appellant had neither filed return of income as per the provisions of section 139(1) of Income Tax Act nor the return of income was filed in response to notice issued under section 148 of Income Tax Act. Moreover, even during the course of assessment proceedings, absolutely no details were filed by the appellant before the AO. Accordingly, it is very important to note that appellant has been totally non-co....
X X X X Extracts X X X X
X X X X Extracts X X X X
....s income of the appellant for the year under consideration is hereby rejected. 7.4 It is incumbent upon the appellant to follow the law of land and it chose to not to follow the law at its own peril. Therefore, I confirm the conclusion drawn by the AO that audited accounts furnished by the appellant is nothing but an afterthought. Consequently, the estimate of income of the appellant at Rs. 6,32,197/- being 1% off the turnover is upheld." 4. Aggrieved against the appellate order, the assessee is in appeal before us raising the following Grounds of Appeal: [1] The Ld. CIT(A), NFAC. Delhi was grievously in upholding the addition made by the Ld. AO of Rs. 6,32,197/- being 1% as net profit of total turnover of Rs. 6,32,19,7....
X X X X Extracts X X X X
X X X X Extracts X X X X
....Rs. 6,32,197/- as the net profit for the Asst. Year 2020-21. The observation of the assessing officer is reproduced as follows: "On perusal of submission of the assessee, it has been noted that The Assessee was worked as Primary Co-operative Society (i.e. Animal Keepers) engaged in Supply of Milk produced by them. The said Cooperative Society is worked under The Banaskantha District Milk Producers Co-Operative Union Ltd, Palanpur in short called as Banas Dairy (Union) as member. The management of the said Co-operative Society is run by the committee and said committee is appointed by the members of Co-operative Society and Co-operative Society is worked on basis of Co-operative method. They collects the milk from members (Animal Ke....