This is a case of wilful evasion of tax.
(vii)........[same as para (vi) has been mentioned in this order].
6.6 From the above discussion ... written submissions before the CIT(A) in which the assessee gave para-wise reply to the various findings and conclusions arrived
following reply has been received:
"2. In this case, earlier para wise reply in the case of Vatva Industries Association
Charitable Trust bearing
alleged observation of
the AO concerning specific shareholders in para 12 of the said reply dated 18.03 2014.
Even it was informed that where ... binding. The appellant had given reply and
made submissions point wise of the notice issued in para 12 of the above letter
para 5 of above reply, the assessee company itself admitted and
shown its difficulty to maintain piece wise, item wise derails in stock register ... company. How cold the quantity tall be possible without
having item wise, piece wise records. Under the circumstances, the defect
pointed out by this office
during the period
relevant to A. Y. 2008-09.
2) Furnish invoice-wise proof of exports, if any, made by the
assessee.
3) Documentary evidences ... Kindly explain the discrepancy".
3. The assessee vide reply dated 30.11.2010 with para wise which
is as under:-
1. During the course of assessment
interest expenses."
In response to which vide letter dated 27.09.2013 assessee replied that amount
of Rs. 199566/- has been shown as income from other sources ... submitted its reply vide letter dated
21.10.2013. The relevant part of assessee's reply is reproduced here as under :-
" Vide Para
meters (Sales) in Annexure-l5 to
Tax Audit Report along-with month-wise receipt of Grey cloth from clients
and delivered to them leaving thereby ... rely on our explanation and evidences furnished in reply dated 15-11-
2016 under Para-12. "
3.4 The reply of the assessee has been
assessee had not been supplied those credit notes till the day reply was filed with the AO.
The AO, however, did not accept this explanation ... assessment order are in the following terms:
That, in view of para wise discussion along with comments, it is held that the book result shown
also allowed in the
past. As noted by A.O. in Para 4.1 the discount and rate difference was
disallowed. Even that disallowance in earlier ... appellant has furnished comparative figures of rate difference year wise and
furnished reply in its letter dated: 28/11/2016, The figures are given
total income, you are
requested to prove a direct party/entity wise nexus between the
borrowed funds (related to interest payment ... should
not be made
Kindly note our reply in below paras.
In the table reproduced on paragraph 4 of show cause
notice, only item
