2025 (2) TMI 1838

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....t order passed under section 143(3) of the Income-tax Act, 1961[hereinafter referred to as "the Act"], by the Assistant Commissioner of Income-tax, Circle 1(1)(2), Ahmedabad [hereinafter referred to as "AO"], for the Assessment Year (AY) 2017-18. Facts of the case: 2. The assessee is engaged in the business of manufacturing machinery and providing installation and maintenance services. The assessee originally filed its return of income on 02.11.2017, declaring a total income of Rs. 54,26,910/-, which was later revised to Rs. 46,67,470/- on 09.02.2018. The case was selected for complete scrutiny under CASS, and the AO assessed the total income at Rs. 3,57,20,270/-, making various additions, including the disallowance of depreciation on....

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....rs appeared in both lists. To substantiate this, the DR referred to the ledger accounts of two specific parties, namely Megamech Engineers and Shree Khodal Engineering, to demonstrate the alleged discrepancy. However, upon a thorough examination of these ledger accounts during hearing, no deficiencies were found, indicating that the AO's observations were not supported by substantive evidence. Regarding the issue of depreciation on the CNC Lathe machine, the DR merely reiterated the AO's findings without bringing any fresh arguments or additional evidence to support the disallowance. 6. The Authorized Representative (AR) countered these arguments, particularly emphasizing that out of the total addition of Rs. 1,82,75,037/- made by th....

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.... of sundry creditors, one for Labour Purchase and the other for Material Purchase and Labour Purchase, and certain creditors appeared in both lists. The Departmental Representative (DR) referred to the ledger accounts of Megamech Engineers and Shree Khodal Engineering, but upon verification, no deficiencies were found. It was further observed that out of the total addition Rs. 1,67,15,471/- pertained to Vishwakarma Engineers, for which the AO had issued a notice under Section 133(6) and made certain additions based on discrepancies observed in the ledger account. The Authorized Representative (AR) argued that since the AO had already identified and adjusted for these discrepancies, treating the entire amount as bogus was neither logical nor....