2026 (4) TMI 33

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....the Respondent : Dr. Ranjit Kaur (Addl. CIT) - Ld. Sr. DR (Virtual) ORDER MANOJ KUMAR AGGARWAL (ACCOUNTANT MEMBER) 1. The assessee has preferred further appeals for Assessment Years (AY) 2017-18 & 2019-20. First, we take up appeal for AY 2017- 18 which arises out of an order of learned Commissioner of Income Tax (Appeals), NFAC [CIT(A)] dated 13-11-2025 in the matter of an assessment fram....

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....to be engaged in manufacturing of wooden articles like Plywood etc. in its proprietorship concern M/s Neelkanth Plywood. Pursuant to search action u/s 132 in the case of Shiv Kumar Plywood group of cases on 04-01-2019, a notice u/s 148 was issued by Ld. AO to the assessee. The search findings alleged that Shiv Shankar group was involved in large scale suppression of sale of plywood, sun mica and o....

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....e Ld. AO, after rejecting assessee's various submissions, computed suppressed sales of Rs. 114.65 Lacs and applied GP rate of 12.5% to make addition of Rs. 14.33 Lacs. 3. During first appeal, the assessee assailed the assessment order on legal grounds as well as on merits by way of elaborate written submissions which have already been extracted in the impugned order. However, Ld. CIT(A) endorse....

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....sons from whom the data was allegedly found and statement of searched party which apparently has never been provided to the assessee. The same is clearly in violation of principles of natural justice and therefore the addition, made in this manner, could not be sustained in the hands of the assessee. In fact, on identical facts similar addition was made by Ld. AO in AY 2018-19 which reached up-to ....