9911796707
TMI Blog2022 (7) TMI 166X X X X Extracts X X X X X X X X Extracts X X X X ..... has taken the following grounds of appeal: "1.That the learned Commissioner of Income Tax Appeals 3 Kolkata confirming the disallowances of loss Rs.23,33,238/- is quite illegal 2. That the learned CIT(A) 3 Kolkata not considered the facts properly 3. That the learned CIT(A) 3 Kolkata not considered all the transaction between the Pvt Ltd and Ltd. Co. 4. That the appellant further craves to add to and leave alter or to amend any of the aforesaid grounds appeals as and when necessary." 2. No one has put in appearance on behalf of the assessee despite service of notice. A perusal of case file records show that several notices have been served in the past to the assessee through Registered post and even through email to the AR of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt order has observed that the appellant is mainly engaged in the business of trading of Agri Commodities, Edible Oil, Vegetable Oil etc. further he detected from the Profit & Loss account for the year under consideration as well as information gathered u/s. 133(6) of the Income-tax Act, 1961, that the following loss has been incurred on purchase and sale: 1 Loss incurred on purchase and sale of Skimmed Milk Powder: Rs.21,73,505.5/- 2 Loss incurred on purchase and sale of Channa Rs. 1,59,732.0/- Total r/o Rs. 23,33,238.0/- Accordingly, the AO issued a show caused letter to the appellant company to explain the matter along with corroborative documents in connection with the above loss. The appellant's reply as submitted befor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eturned un-served. The AO therefore observed that the appellant company entered into an arrangement in which any transaction, where money has changed hands but any real trading activity did not occur. During the course of the appellate proceedings it has been submitted by the A/R of the appellant that the AO has not brought any independent and reliable evidence. However, it observed that the A/R has also failed to controvert the basic findings of the AO. The AR, vide order sheet noting dated 29.04.2019 stated that no evidences could be furnished for movement and delivery of the commodities (Channa and Skimmed Milk Powder) in which the losses have been shown. The AO has discussed in detail and brought out the factual matrix of circular tradi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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