section 271(1)(c) , any person, who failed to offer valid explanation, the
amount added directly on indirectly to the total income of an assessee ... section 271(1)(c) any person, who fails to offer valid explanation in
respect of any addition, the amount added directly or indirectly
Dcit Cent. Cir. -5(3) (Erstwhile Dcit ... vs Modern Road Makers Pvt. Ltd., Mumbai on
alleged hawala purchases were
booked, for which the appellant could not offer any valid explanation.
These facts clearly established that the appellant had suppressed ... compliance, the Ld. AR could not offer any valid reasons for
fall in the GP rate. Considering the facts in entirety I the appellant being
seller has acknowledged
offer by way of an acceptance. Therefore, the offer and
acceptance would give rise to a valid contract between the
parties ... conditions of purchase of property. If, date of
letter of offer is considered as valid agreement to sell, holding
period of the asset is more
alleged hawala purchases were booked, for which the
appellant could not offer any valid explanation. These facts clearly established that
the appellant had suppressed ... compliance, the Ld. AR
could not offer any valid reasons for fall in the GP rate. Considering the facts in
entirety and relying on decisions
alleged hawala purchases, were booked, for which the appellant
could not offer any valid explanation. However, after disallowance
of bogus purchases, the GP in these ... respectively. In compliance, the Ld AR
could not offer any valid explanation. These facts clearly establish
the fact that appellant had suppressed its profits
cash, so far as the same has been validly declared
in his books of accounts and offered for tax purpose.
5. Thus addition made under ... their bank account and as and
when earned, it has been validly offered for tax purpose too."
3. The relevant facts in brief
Assessment Year 2019-2020
Since the Appellant was not unable to offer valid explanation
regarding the balance cash of INR.13,01,400/-, the same
present case undisputedly the assessee has not
maintained books and has offered his business income to tax on presumptive
basis u/s 44AD ... assessee for any previous year and the assessee fails to offer valid explanation
for credit of such sum in the books or explanation offered
present case
undisputedly the assessee has not maintained books and has offered his business
income to tax on presumptive basis u/s 44AD ... assessee for any previous year
and the assessee fails to offer valid explanation for credit of such sum in the books or
explanation offered