2026 (5) TMI 1130

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....presented : Shri Arun Kanti Datta - CIT DR ORDER PER BEENA PILLAI, JUDICIAL MEMBER: This appeal is filed by the assessee against the order passed by the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as the Ld. CIT(A)], dated 31/10/2025 for the A.Y. 2022-23, on the following grounds of appeal:- "1. The Ld. CIT(A) erred in confirming addition made by the Ld....

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.... 2. The assessee is a Private Limited Company engaged in wholesale trading of medicines and also acting as a Carrying & Forwarding (C&F) Agent for pharmaceutical companies. In such capacity, the assessee sells goods at prices fixed by the principal companies and earns only commission income. 2.1. During the assessment proceedings, the Ld. AO observed a discrepancy between purchases reflected i....

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....A), assessee is in appeal before this Tribunal. 3. Before us he Ld. AR submitted that the assessee is merely acting as a C&F Agent and the figures reflected in GST returns include agency transactions which do not constitute purchases of the assessee. It was submitted that proper reconciliation explaining the difference is available and can be substantiated with supporting documents. It was furt....

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.... transactions and stock transfers. We note that the reconciliation explaining such difference has not been properly verified by the authorities below. The addition appears to have been made merely on the basis of mismatch without appreciating the nature of the assessee's business. 4.1. We further note that, the additions made u/s 68 in respect of loan creditors and sundry creditors are primaril....