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TMI Blog2019 (3) TMI 913X X X X Extracts X X X X X X X X Extracts X X X X ..... -examination of Shri Har Narayan Gupta, he has clearly and categorically denied that he indulged in any kind of mal-practice. He also denied to make any statement that he was only getting commission for issuing bills with actual sale to respondent – assessee. In view of the categorical findings of fact recorded by the Commissioner of Income Tax in favour of the respondent – assessee in appeal and confirmed by the Tribunal vide impugned order, no question of law arises in the present appeal. Moreover, the authorities below have recorded that M/s Annapurna Trading Company has produced its books of account in the reassessment proceedings and the same were verified by the Assessing Authority. The quantity and details, furnished by the res ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... into consideration the facts and circumstances of the case and all the material on record? The facts of the case are that the respondent assessee is running a roller flour mill unit for manufacturing trading of Aatta, Maida and Suji and also, running manufacturing unit of biscuits on job work basis for Parle Biscuit Private Limited, Mumbai. On 26.10.2012, the respondent assessee filed its income tax returns showing income of ₹ 1,07,12,440/-. On 23.08.2011, the assessment was completed under section 143(3) of the Income Tax Act, 1961 at a total income of ₹ 1,10,64,630/-. Thereafter, information was received from ADIT-3, Kanpur that one Shri Har Narayan Gupta, the Proprietor of M/s Annapurna Trading Company, K ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and perused the records of the case. The proceedings under sections 147/148 of the Income Tax Act have been initiated against the respondent assessee on the basis of information received from ADIT-3 and statement of Shri Har Narayan Gupta, the Proprietor of M/s Annapurna Trading Company, was recorded to the effect that he has only received commission from the respondent assessee without there being any actual sale. In turn, the purchases of ₹ 4,19,94,000/- shown by the respondent assessee were bogus and only a bogus purchase entry was made to reduce actual tax liabilities. In pursuance of the summons and on crossexamination of Shri Har Narayan Gupta, he has clearly and categorically denied that he indulged in any kind of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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