9911796707
TMI Blog2021 (9) TMI 1084X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Assessing Officer. Appeal filed by the assessee is allowed for statistical purposes. - ITA No. 304/Bang/2021 - - - Dated:- 20-9-2021 - George George K., Member (J) For the Appellant : K.Y. Ningoji Rao, CA For the Respondents : Ganesh R. Ghale, Standing Counsel ORDER This appeal at the instance of the assessee is directed against the CIT(A)'s order dated 14.08.2017. The relevant assessment year is 2006-2007. 2. There is a delay of 497 days in filing this appeal. The assessee has filed a petition for condonation of delay along with an Affidavit stating therein the reasons for delayed filing of this appeal. The reasons stated in the Affidavit for belated filing of this appeal is that the assessee for ident ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e attributed to any latches on the part of the assessee. There is sufficient cause in the facts and circumstances of the case to condone the delay in filing this appeal. Accordingly, the delay in filing this appeal is condoned and I proceed to dispose of the appeal on merits. 3. The solitary issue argued was that whether the CIT(A) was justified in upholding the addition of ₹ 3,84,730 disregarding that the impugned amount was offered to tax by the assessee in assessment years 2007-2008 and 2008-2009, which tantamount to double taxation. 4. The brief facts of the case are as follows:- The Assessing Officer, during the course of assessment proceedings, noticed difference in purchase by the assessee from M/s. Ajay's Bangalo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... AR has filed a paper book comprising of 152 pages enclosing therein copies of the invoices made out by M/s. Ajay's Bangalore to the assessee towards the sale of goods, copy of the ledger account of M/s. Ajay's Bangalore for the financial year 2005-2006, 2006-2007 and 2007-2008, copy of the audited annual statement, copy of the rectification application filed before the CIT(A), copy of the communications with the CIT(A) (CPC) and various case laws relied on by the assessee. The learned AR reiterated the submissions made before the Income Tax Authorities. 7. The learned Standing Counsel supported the orders of the Assessing Officer and the CIT(A). 8. I have heard rival submissions and perused the material on record. The assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... for the A.Y. 2007-08. Refer audited Annual Accounts at marked pages 95 to 116 of the paper book and the profit and loss account at marked page 99 of the paper book. 7. The copy of the printout of ledger account of M/s. Ajay's of Bangalore, as appearing in the appellant's books of account, for the financial year 2005-06 reflects a sum of ₹ 2,93,544/- was accounted as income for the A.Y. 2006-07 by way of discounts and rebates from M/s. Ajay's Bangalore. Refer ledger account at marked pages 77 to 83 and at pp 82 and 83 of the paper book. 8. The copy of the printout of ledger account of M/s. Ajay's Bangalore, as appearing in the appellant's books of account, for the financial year 2006-07 reflects a sum of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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