TaxTMI 
TaxTMI 
2026 (6) TMI 482
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....e assessee has raised the following grounds of appeal: "1. The order passed by the learned Hon'ble Commissioner of Income Tax (Appeals)/NFAC is erroneous both in law and on facts. 2. The learned Hon'ble Commissioner of Income Tax (Appeals)/NFAC has erred in law and on facts in confirming the addition made by the A.O on account of unexplained expenses as per the assessment order dated 21.03.2025. 3. Any other grounds that may be urged at the time of hearing is hereby kept open" 3. The brief facts of the case are that the assessee is a company engaged in the business of manufacture of explosives and site mixed emulsion. The assessee filed its return of income for Assessment Year 2023-24 on 31.10.2023 decl....
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....s with regard to the addition of Rs. 68,47,010/- made by the Ld. AO by disallowing the purchases under section 37(1) of the Act treating the same as bogus purchases. The Ld. AR submitted that the Ld. AO has treated the purchases made from M/s Core India Corporation as bogus merely on the ground that the said creditor did not respond to the notice issued under section 133(6) of the Act. The Ld. AR further submitted that the assessee had maintained proper books of account which were duly audited by the Chartered Accountant in accordance with the provisions of the Act. Inviting our attention to page no.5 of the assessment order, the Ld. AR submitted that the Ld. AO himself has recorded that the assessee had furnished copies of audited accounts....
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....bmitted that there is no infirmity in the orders of the lower authorities in treating the purchases as bogus and disallowing the same under section 37(1) of the Act. 7. We have heard the rival submissions and perused the material available on record. We have gone through page no.5 of the order of the Ld. AO, which is to the following effect: In response to the notices u/s. 142(1) of the Income Tax Act, 1961 dated 12.07.2024 and 12.02.2025, the assessee submitted copies of audited account, bank statement and cash flow statement, purchase details, invoices, raw material purchase, bank statements, stock valuation and ledger rent which was perused and considered. On observation of Balance sheet, it is seen that the assessee....
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....from Core India Corporation (PAN - AMTPS1780Q) during the year is considered as bogus and the same is disallowed u/s. 37(1) of the Income Tax Act, 1961. [Disallowance: Rs. 68,47,010/-] 8. On perusal of the above, we find that the Ld. AO himself has recorded the fact that the assessee had submitted copies of audited accounts, bank statements, cash flow statements, purchase details, invoices, raw material purchase details, stock valuation and ledger accounts during the course of assessment proceedings. Accordingly, it is evident that all the primary documents in support of purchases were furnished by the assessee before the Ld. AO. We have also gone through the confirmation issued by M/s Core India Corporation placed at page no.28....