2025 (3) TMI 2279

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....Advocate) - Ld. AR ORDER MANOJ KUMAR AGGARWAL (ACCOUNTANT MEMBER) 1. Aforesaid appeal by revenue for Assessment Year (AY) 2014-15 arises out of an order of learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [CIT(A)] dated 28-06- 2024 in the matter of an assessment framed by Ld. Assessing Officer [AO] u/s. 147 r.w.s. 144B of the Act on 28-03-2022. B....

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....in ICICI Bank current account was for Rs. 747.38 Lacs. It transpired that the account was credited with high volume transfers from an entity followed by immediate cash withdrawals through cheque. The assessee did not maintain any sale/ purchase bills or vouchers. The assessee reflected purchases of Rs. 89.07 Crores which, according to Ld. AO, remained unverified. Accordingly, 12.5% of these purcha....

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....l facts before Ld. AO to hold that the purchases were not genuine. The purchases so made by the assessee were duly accounted for in the return of income which was duly verified during scrutiny assessment proceedings. There was no tangible material to reopen the case of the assessee and accordingly, the reassessment proceedings were quashed and legal grounds as raised by the assessee were allowed. ....

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....rified and Ld. AO substantially accepted the return income. Subsequently, the case was reopened pursuant to receipt of certain information from investigation wing alleging that there was large debit and credit in the bank account. However, this account was disclosed account and no enquiries were conducted by Ld. AO to arrive at conclusion of escapement of income. The case was reopened at the behes....