The
assessee preferred an appeal against the order passed by the National Faceless
Appeal Centre for Assessment Year 2019-20, arising out of reassessment
proceedings completed under section 147 read with sections 144 and 144B of the
Income-tax Act, 1961. The grievance of the assessee was confined to the action
of the Assessing Officer in treating purchases amounting to ₹36,12,300 as bogus
and making a 100 percent addition, which was sustained solely on account of
dismissal of the first appeal on the ground of limitation.
The
assessee contended that both the assessment proceedings and the appellate
proceedings were conducted ex-parte without effective service of notices. It
was submitted that the registered email address and mobile number on the
income-tax portal belonged to the assessee’s erstwhile tax consultant, and due
to the consultant’s ill health, advanced age, and lack of technical
proficiency, the statutory notices remained unattended. Consequently, the
assessment was completed ex-parte, and the assessee became aware of the same
only upon receipt of the notice of demand.
There
was a delay of 295 days in filing the appeal before the Commissioner (Appeals),
for which the assessee filed a detailed petition for condonation of delay
supported by a sworn affidavit explaining the circumstances leading to such
delay. The learned CIT(A), however, dismissed the appeal solely on the ground
that the appeal was barred by limitation, without condoning the delay.
The
Tribunal observed that the explanation furnished by the assessee disclosed
sufficient cause for the delay. The assessee was a lay individual dependent on
professional assistance, and the failure to respond to statutory notices could
not be regarded as deliberate or contumacious. The Tribunal further noted that
once the delay was condoned, the addition on account of alleged bogus purchases
required reconsideration, as it is a settled principle that where purchases are
recorded in the books of account, payments are made through banking channels,
and corresponding sales exist, a 100 percent addition cannot be made
mechanically without proper verification.
In
the present case, the Assessing Officer had made a blanket addition of the
entire purchase amount without undertaking a holistic examination of the books
of account and supporting material. In the interest of justice, the Tribunal
condoned the delay of 295 days, set aside the impugned appellate order, and
restored the matter to the file of the Assessing Officer for fresh adjudication
on merits after affording due and effective opportunity of being heard to the
assessee.
Accordingly,
the appeal of the assessee was allowed for statistical purposes.
Source Link- https://itat.gov.in/public/files/upload/1768213776-EUVxfy-1-TO.pdf
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