2026 (2) TMI 555

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ltiple grounds of appeal which are reproduced as below: "1.1 That on the facts and circumstances of the case, the CIT(A) has erred in upholding the addition of Rs. 1,24,89,146/- and deciding the appeal ex-parte without affording proper and reasonable opportunity of being heard in violation of the principles of natural justice. 1.2 That the CIT(A) has acted arbitrarily in deciding the appeal ex-parte without ensuring service of any physical or effective notice of hearing, thereby depriving the Appellant of its right to present its case. 2.1 That on the facts and circumstances of the case, the Assessing Officer was not justified in issuing the Notice u/s 148A(b) and subsequently passing the Order u/s 148A(d) of the ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....That the allegation of non-genuine purchases of Rs. 1,24,89,146/- being based purely on surmises and conjectures and in absence of any independent enquiry/investigation, the entire basis of reopening is mechanical and bad in law. 4.1 That on the facts and circumstances of the case, the CIT(A) was not justified in confirming the disallowance of Rs. 1,24,89,146/- made u/s 37(1) of the Income Tax Act, 1961 on the alleged ground of non-genuine purchases, without properly appreciating the totality of facts and in complete disregard of the documentary evidence placed on record. 4.2 That statement of Sh. Sumit as referred to in the Re-Assessment order having been recorded at the back of the Appellant Company is of no relevance an....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ts. Therefore, we, first take up the Grounds on merits i.e., No. 4 & 5. 3.1 Brief facts are that the assessee filed return for A.Y. 2018-19 on 23.09.2018 declaring income of Rs. 16,40,510/-. Subsequently, on receipt of information regarding bogus accommodation entries taken by the assessee, notice u/s 148A(b) was issued on the ground that the transactions amounting to Rs. 1,20,25,868/- represented bogus purchases from M/s Madan Lal Madho Prasad and Kalki Trading Company. As no response was received to the show cause notice dated 12.03.2022, Ld. AO passed an order u/s 148A(d) and also issued notice u/s 148 on the ground that income amounting to Rs. 1,20,25,868/- had escaped assessment. Subsequently, assessment was finalized vide order u/s....