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2. In various grounds of appeal, the assessee has contented that the CIT(A) erred in misinterpreting the working of reconciliation with M/s Aqua Trade Global Logistics Pvt Ltd, M/s Baron Shipping & Logistics Pvt Ltd. & M/s Wan Hai Lines Limited. He erred in understanding the reconciliation of the party Aqua Trade Global Logistics Pvt Ltd and also erred in understanding that the difference of Rs. 17,60,131/- was account of GST being included in the ledger given by the party. He erred to accept the confirmation filed by the Aqua Trade Global Logistics, showing this difference as GST received and included in the total. The CIT(A) erred to take into the account the GSTR 2B showing the purchases which include the details M/s Aqua Trade Global Logistics.The CIT(A) erred in not considering the reconciliation of the party M/s Baron Shipping & Logistics Pvt Ltd. given during the Assessment proceedings and also erred in not considering the Ledger confirmations given during the Assessment proceedings. The CIT(A) erred in not considering the reconciliation of the party M/s Wan Hai Lines Limited given during the Assessment proceedings and also erred in not considering the ledger and copies of invoices given during the Assessment proceedings by the Appellant. The CIT(A) erred in not taking into consideration the working of reconciliation and how the same has led to the difference of Rs. 91,488/- with the ledger A/c of the party M/s Wan Hai Lines Limited.

i. Aqua Traders Global Logistics Rs. 17,60,131/- 
      ii. Baron Shipping Logistics               Rs. 21,000/-

      iii. Wan Hi Lines Ltd.                     Rs. 91,488/-

                   TOTAL                       Rs. 18,72,619/-
4. It is noticed from the assessment order that in respect of AQUA TRADERS GLOBAL LOGISTICS, it was noticed by the AO that the assessee had purchase made during the year of Rs.1,45,00,636/-

( Rs.9,14,980-1,54,15,616/-) but the said party had sold to the assesse of Rs.1,27,40,505/-. So, there was difference of Rs.17,60,131/-. He observed that the assessee failed to reconcile and also did not file any explanation in this regard. Hence, the amount of Rs. 17,60,131/- was added to the income of the assessee as unexplained expenditure which was not considered in the books of accounts.

Page |4 A.Y. 2022-23 Jaguar Shipping and Logistics Pvt. Ltd.

4.1 In the case of BARON SHIPING LOGISTICS, the AO noticed that the said party had shown sales to the assessee company during the year of Rs.14,65,750/- whereas it had shown purchase from that party of Rs.14,44,750/-. In view of this, the difference of Rs.21,000/- was considered as transaction out in the books of accounts and was added to the income of the assessee as unexplained expenditure.

4.2 In the case of WAN HI LINES LIMITED, it was noticed by him that the above party had shown sales made to the assessee during the year of Rs.6,83,280/- whereas it disclosed purchase from them of Rs.5,91,792/-. In view of this, the difference of Rs.91,488/- being excess transactions was added to the income of the assessee as unexplained expenditure which was not considered in the books of accounts.

5. In the subsequent appeal by the assessee before the ld.CIT(A), so far as the difference in the case of Aqua Traders Global Logistics is concerned, it was submitted by the assessee that the difference of Rs. 17,60,131/- was the GST amount which was included in the sales, by this party, but in their account this amount was excluding the GST. So far as Baron Sipping Logistics of Rs. 21,000/- and Wan Hi Lines Ltd. of Rs. 91,488/-are concerned, it was submitted that the assessee was not aware Page |5 A.Y. 2022-23 Jaguar Shipping and Logistics Pvt. Ltd.