Merely because the Assessee did not submit a reply at the appropriate stage cannot, on the facts of this case, lead to any adverse conclusion against the Assessee

It happens in general that AO make addition on the ground that assessee did not submit the reply to the query raised by him in time. In a similar matter [reported in 2008 -TMI - 3577 - HIGH COURT OF DELHI], honorable high court observed that,

Learned counsel for the Revenue submitted that it has been recorded by the Assessing Officer that the Assessee was asked to state as to why the provision for doubtful debts etc. has been added back for the purposes of computing profit under Section 115-JB of the Act but the Assessee did not submit any reply and, therefore, the adjusted book profit had to be increased by the amounts set aside for provisions made for meeting liabilities, other than ascertained liabilities. We are of the view that this observation cannot be of much assistance to learned counsel for the Revenue, particularly in view of the facts and the law that we have discussed above. Merely because the Assessee did not submit a reply at the appropriate stage cannot, on the facts of this case, lead to any adverse conclusion against the Assessee. 

2008 -TMI - 3577 - HIGH COURT OF DELHI