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2024 (7) TMI 659

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..... d a presentation, wherein, inadvertently, the petitioner failed to remove double entries relating to payments reflected in journal entries in the head and branch offices HELD THAT:- As petitioner has placed on record the relevant e-mail, which prima facie shows that invoices from 30 vendors are attached as PDF's. Petitioner contends that the discrepancy in purchase value would stand fully reconciled if these invoices are examined conjointly with the reconciliation statement. This makes out a case for reconsideration. Because the petitioner had sufficient opportunity, including a personal hearing, and failed to provide all these documents in time, it is just and necessary that costs be imposed on the petitioner. The impugned order is set .....

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..... om about 61 vendors. During assessment proceedings, she submits that the petitioner submitted a presentation, wherein, inadvertently, the petitioner failed to remove double entries relating to payments reflected in journal entries in the head and branch offices. If the invoices and the reconciliation statements are examined, she submits that it would be clear that the value of purchase from each vendor corresponds to the confirmation letter provided by the vendor concerned. 4. Mr. A.P.Srinivas, learned senior standing counsel, appears on behalf of the respondent. By referring to the impugned assessment order, he points out that at least two notices were issued under Section 142(1) and the assessee was provided sufficient opportunity to subm .....

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..... an be seen that various opportunities were provided to the assessee to substantiate its claim towards purchases made from the above parties, however, the assessee has not submitted any invoice copies towards the purchases made. The above paragraphs disclose that the invoices were not accessible to the assessing officer. 6. The petitioner has placed on record the relevant e-mail, which prima facie shows that invoices from 30 vendors are attached as PDF's. Learned counsel for the petitioner contends that the discrepancy in purchase value would stand fully reconciled if these invoices are examined conjointly with the reconciliation statement. This makes out a case for reconsideration. Because the petitioner had sufficient opportunity, incl .....

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