9911796707
TMI Blog2024 (3) TMI 315X X X X Extracts X X X X X X X X Extracts X X X X ..... ally requested - HELD THAT:- Petitioner is correct in stating that these details were never asked for in the notice issued u/s 148A(b) of the Act or later. Petitioner is also correct in submitting that for the first time in this order there is even an allegation that investigation by Central Goods and Service Tax Department revealed that KMPL was indulging in non-genuine transactions and was merely passing accommodation entries. Therefore, the business that Petitioner had with KMPL was only on paper. There is an observation that Assessee has shown sales to KMPL in its books of account which is non-genuine. There is nothing to indicate how the AO has come to such a conclusion notwithstanding accepting the fact that Petitioner had submitted c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ) of the Act alleging that there was information suggesting income chargeable to tax for AY 2019-20 has escaped assessment. The information was enclosed with the notice. It was alleged that a sum of Rs. 3,64,97,625/- could have escaped assessment. 4. Thereafter, Petitioner received a notice dated 15th March 2023 again under Section 148A(b) of the Act. The details of information was annexed with the notice in which it was admitted by Respondents that the earlier notice dated 4th March 2023 was sent containing incorrect information and, therefore, should be treated as invalid. This new notice contained brief details of information collected/received by the Assessing Officer ( AO ). The information was Petitioner was a beneficiary of accommoda ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... was only on paper. There is an observation that Assessee has shown sales to KMPL in its books of account which is nongenuine. There is nothing to indicate how the AO has come to such a conclusion notwithstanding accepting the fact that Petitioner had submitted copy of financial statement, ledger details, ledger account details of GST sales in respect of tax invoices of all parties and copy of bank statement of HDFC Bank through which KMPL had made payment. Mr. Deshpande also pointed out that the AO in his order impugned has stated Petitioner failed to submit E-way bills whereas in the letter dated 20th March 2023 at Annexure A is a copy of the tax invoices and E-way bills. Mr. Deshpande also submits that perhaps the toll booth receipts may ..... X X X X Extracts X X X X X X X X Extracts X X X X
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