2025 (6) TMI 2163

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....CIT(A)" for short) dated 25.03.2023 passed under Section 250 of the Income-tax Act, 1961 [hereinafter referred to as "the Act" for short], for Assessment Year (AY) 2014-15. 2. The grounds of appeal raised by the Assessee are as follows:- "1. The learned CIT(A) has erred in law and on facts of the case in confirming action of ld AO of reopening the assessment u/s 147 of the Act. Under the facts and circumstances of the case, the action of reopening is without jurisdiction and in not permissible either in law or on facts. 2. The learned CIT(A) has erred in law and on facts of the case in confirming action of ld AO in making disallowance of Rs. 43,48,272/- u/s 37 of the Act. The learned CIT(A) failed to appreciate that the....

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....has erred in law and on facts of the case in confirming action of the ld. AO in levying interest u/s. 234A/B/C/D of the Act. 8. The learned CIT(A) has erred in law and on facts of the case in confirming action of the Id. AO in initiating penalty proceedings under Section 271(1)(c) of the Act." 3. In this case, return of income was filed on 28.11.2014 declaring total income at Rs. 98,32,060/-. The return was selected for scrutiny and order u/s 143(3) of the Act was passed on 25.11.2016 at Rs. 98,32,060/-. Thereafter, the case was reopened vide order No. Pr.CIT(A)/Approval u/s 147/DCP/2018-19/2488 dated 25.02.2019. On 28.03.2019, notice u/s 148 of the Act was issued to the assessee to file a new return of income for the AY 2014-15....

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....,000/- Rs.3,37,050/- Sugar Rs. 1,49,11,600/- Rs.1,51,88,800/- Rs.2,77,200/- Total Rs.5,36,17,450/- Rs.5,45,43,550/- Rs.9,26,100/- Thus, the undisputable facts in this case are that, ● The transaction value of the alleged client code modification was Rs. 5,45,43,550/-, against the purchases of Rs. 5,36,17,450/-. ● The profit earned out of these transactions was Rs. 9,26,100/-. 6. The Ld. AR vehemently argued that ⮚ these transactions have been accounted for in the books of accounts. ⮚ the profit element embedded therein has been offered for tax. ⮚ such profit disclosed by the assessee has been accepted by Assessing Officer. ....