TaxTMI 
TaxTMI 
2026 (4) TMI 1459
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....011-12 dated 21.11.2024. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: "1. For that, on the facts and in the circumstances of the case, Ld. CIT(A) was not justified in passing an ex-parte order without giving reasonable opportunity of hearing. 2. (a) For that the Ld. CIT(A) ought to have held re-opening proceedings u/s 147/144 to be invalid and was liable to be quashed. (b) For that the Ld. CIT(A) failed to consider that the Jurisdictional A.O. lacked jurisdiction to issue notice u/s 148 in view of the provisions of section 151A r.w.s. notifications issued there under, thereby vitiating the reassessment order. 3. For that the Ld. CIT(A) ought to have held tha....
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....(1) of the Act were also issued and in response to the said notices, the assessee filed various documents. The Ld. AO noted that the assessee company had paid Rs. 1,01,00,000/- to M/s. Jagannath Enterprise during the FY 2010-11 against lorry hire charges of Rs. 1,06,02,158/-. The same amount was withdrawn on the same day or the very next day. Since the genuineness of the transaction was not established, the Ld. AO treated the transaction as bogus expenditure and added back the same to the total income of the assessee and assessed the total income of the assessee at Rs. 1,13,14,998/- u/s 147/144 of the Act. Aggrieved with the assessment order, the assessee filed an appeal before the Ld. CIT(A) who perused the material available on record and....
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....ings the appellant filed response vide letter dated 15.07.2024 on jurisdictional grounds and relying upon the various case laws but the appellant was unable to justify his contention on merits of the case. c) The Assessing Officer, during the assessment proceedings had made detailed verification and enquiry by issuing notice u/s 133(6) of the Act and also by issuing summons u/s 131 of the Act to the Director of the appellant company. Moreover, the AO has appropriately and in detail explained the reasonings behind additions made. The AO has made verification and enquiry before the addition made and the relevant part of the assessment order is reproduced here below :- "9 From the ledger account of Jagannath Enterprises as su....
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....company. In view of the above, the expenditure claimed amounting to Rs 1,06,02,158/- through bogus billing is treated as bogus expenditure and not laid out for the purposes of business and hence disallowed and added back to the total income of the assessee." d) In view of the above facts and circumstances and after taking into consideration the reply of the appellant, I am in agreement with the finding of the Assessing Officer and hold that the appellant is unable to substantiate its claims and is not able to controvert the assessment order. The addition made by the Assessing Officer is therefore confirmed. 5.5 The appellant has not been able to defend the grounds raised. Hence, grounds raised are rejected. 6. In ....