2025 (2) TMI 1543

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....7.2024 passed against the assessment order by Assessing Officer, Circle - 4(3)(1), Mumbai, u/s. 143(3) of the Income-tax Act (hereinafter referred to as the "Act"), dated 30.12.2019 for Assessment Year 2017-18. 2. Grounds taken by the assessee are reproduced as under: Addition of Rs. 2,03,00,000/- made under section 69A of the Act is unjustified 1. The National Faceless Appeal Centre, New Delhi [hereinafter referred to as "NFAC"] erred in confirming the action of the Assessing Officer in making addition of Rs. 2,03,00,000/- by treating the cash deposited into bank as unexplained money without appreciating that the Appellant has duly explained the nature and source of the said cash deposits. Thus, the provisions of secti....

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....laining the modus operandi of its business, assessee submitted that it purchases jewellery locally in the wholesale market and sells the same across the country. Assessee to promote its products in the competitive market, entered into a Merchant Agreement on 18.04.2015 with NOSPL Online Shopping Pvt. Ltd. (hereinafter referred to as NOSPL). NOSPL is an established Company which provides shopping platform to people on internet, print and other alternate channels. It was an understanding between the assessee and NOSPL that NOSPL, would promote assessee's products on e-commerce to increase its sales. 3.1. Apart from sales through NOSPL, assessee also made sales to other parties directly. It is pertinent to mentioned that, out of total s....

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....0,46,9521- (8% of Rs. 31,30,86,912/-). Assessee strongly objected the observations made by ld. Assessing Officer and mentioned that this is merely on the basis of conjecture and surmises without appreciating the facts and circumstances of the case. As per assessee, during the year under consideration, purchases made are of Rs. 21,29,58,169/- which is duly reflected in the books of accounts. Assessee submitted that its total sales turnover during the year under consideration is of Rs. 31,30,86,912/- which consists of Rs. 28,37,73,940/- as credit sales and of Rs. 2,93,12,972/-as cash sales. Also, that out of total sales, sales of Rs. 25,39,78,529/-were executed through NOSPL and the remaining Rs. 5,91,08,383/- were affected through other part....

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....he addition made on account of estimation of profit by applying 8% of Rs. 31,30,86,912/- to arrive at an addition of Rs. 2,50,46,952/-. 4. Before us, facts as stated above were reiterated, by making reference to corroborative material placed on record, in the paper book containing 92 pages. We have perused the records in this respect. Admittedly, it is a fact on record that there is significant increase in the turnover of the assessee from Assessment Year 2016-17 onwards, i.e., after entering into merchant agreement with NOSPL, as depicted in the details tabulated above. We have gone through the observations of ld. CIT(A) corroborated by documentary evidences and do not find any reasons to interfere with the same. In the result, grounds ....