9911796707
TMI Blog2023 (10) TMI 1022X X X X Extracts X X X X X X X X Extracts X X X X ..... ver by delayed filing of the appeal. In our opinion, the substantial delay was for COVID pandemic and other technicalities and therefore the assessee needs to be given a fair chance to represent its case on merit. Considering these facts, we are inclined to condone the delay and admit the appeal for adjudication. Estimation of income - Bogus purchases - AO after receiving information from DDIT (Inv.), Kolkata that Sri Sanjiw Kumar Singh is providing accommodation entries and the assessee is the beneficiary of the same - HELD THAT:- As in the case of bogus purchases the entire purchases cannot be added to the income and only profit element embedded in the said purchases can be added. In the similar type of cases, the various Coordinate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as filed condonation petition explaining the reasons attributable to late filing of the appeal of the assessee. We observe from the condonation petition that the delayed filing of the appeal was on account of non-receipt of appellate order passed by Ld. CIT(A). We note that the order was passed by Ld. CIT(A) before the COVID-19 restrictions set in and was not received by the assessee. The assessee came to know only in the month of March, 2021 when the assessee s representative visited the office of Ld. CIT(A). Then the assessee applied for the copy of the order vide letter dated 23.03.2021 and thereafter again the assessee applied vide letter dated 13.07.2021 27.04.2023 but the office of Ld. CIT(A) failed to supply the copy of the appella ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... from seven parties the details of which are given at page no. 7 of the assessment order which were controlled by Sri Sanjiw Kumar Singh. The AO added the entire purchases to the income of the assessee when the assessee failed to produce the stock registrar substantiating the fact that goods were in fact received by the assessee and used in the manufacturing of goods. Ld. CIT(A) confirmed the order of the AO on the ground that the assessee has failed to prove the purchases with cogent evidences. 5. After hearing the rival contentions and perusing the material on record, we find that the assessee is in the business of manufacturing of electrical goods and aluminium items. The AO after receiving the information from DDIT (Inv.), Kolkata ca ..... X X X X Extracts X X X X X X X X Extracts X X X X
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