Professional Documents
Culture Documents
MINISTRY OF FINANCE
INCOME TAX DEPARTMENT
To,
PARUL GARG
318/5/16 GURGAON ,SHIVAJI NAGAR -
GURGAON 122001 ,Haryana
India
*ITBA100054899363*
Show cause Notice as to why the proposed variation should not be made
Kindly refer to ongoing assessment proceedings in your case for the Assessment Year 2021-22.
2. The following variation(s) prejudicial to your interest are proposed to be made in your case:-
Response
of the Response
Date of Date of
Type of notice/ Date of notice/ assessee type Remarks
compliance response if
communication communication received/ (Full/part/ if any.
given received
not adjournment)
received
Note:- The website address of the e-filing portal has been changed from www.incometaxindiaefiling.gov.in to www.incometax.gov.in.
AKIPG0472G- PARUL GARG
A.Y. 2021-22
ITBA/AST/F/143(3)(SCN)/2022-23/1047807373(1)
2. Variation proposed -
The case was selected for Complete Scrutiny assessment under CASS on the following issues:-
Business purchase
2.2 Synopsis of all submissions of the assessee relating to the issue and indicating the dates of
submission.
During the assessment proceedings the assessee filed its part reply on the date mentioned above. In
its reply the assessee submitted its business activities, computation of income, Audit Report, Proit &
Loss Account, Balance Sheet, Bank Account details, Details of sale and purchase, Details of sundry
creditors, GST Returns etc.
Notice u/s 133(6) was issued to the sellers from whom the assessee has made purchase.
2.4 Variations proposed on the basis of inference drawn (specify the basis of inference and quantify
the variation proposed, if possible).
1. The case was selected for Complete Scrutiny assessment under CASS for the reason Business
purchase.
During the assessment proceedings you have submitted the details of purchase made during the A.Y.
2021-22. From your submission it is found that you have made the purchase from the following persons
as under :-
Sl. Purchase
Name GST No.
No. Amount (Rs.)
Page 2 of 16
AKIPG0472G- PARUL GARG
A.Y. 2021-22
ITBA/AST/F/143(3)(SCN)/2022-23/1047807373(1)
07CDXPB2786E2Z7
5. M/s Bharti Traders (Bharti) (CDXPB2786E) 3270806
06AAQPG5917J1ZE
M/s Garg Steel (Prop.- Manju Garg) (PAN -
10. 2996919
AAQPG5917J)
Page 3 of 16
AKIPG0472G- PARUL GARG
A.Y. 2021-22
ITBA/AST/F/143(3)(SCN)/2022-23/1047807373(1)
BDVPJ3780K)
07CIBPG9976N1ZH)
During the assessment proceedings you were requested to furnish the following documents:-
You have failed to furnish all the above documents. You have submitted only ledger accounts of the
sellers from whom you have made purchase during A.Y. 2021-22. Mere submission of ledger accounts
without supporting documents is not enough to prove the purchase. In absence of any supporting
evidences your purchase could not be proved to be genuine. On verification of materials available on
record following observations are made.
Page 4 of 16
AKIPG0472G- PARUL GARG
A.Y. 2021-22
ITBA/AST/F/143(3)(SCN)/2022-23/1047807373(1)
From your submission it is found that you have made purchase of Rs. 2736653/- from M/s Sharma
Traders.
You have not submitted any purchase bills, transportation details, delivery challans, bank details of the
seller regarding M/s Sharma Traders.
During the assessment proceedings, for gathering information notice u/s 133(6) was issued to M/s
Sharma Traders on 15.11.2022. In response to the notice Shri Piyush Sharma (Prop.- M/s Sharma
Traders) filed its reply on 16.11.2022.
I am a salaried person, this is 100% fraud, I never applied for GST number nor allotted gst
number. I have lodged a FIR in cyber crime Acknowledgement Number 20808220046355
dated: 27.08.2022 and also informed to GST department from where such gst no was
issued.
As per your submission GST number of M/s Sharma traders is 07BOEPS6530Q1Z9. The GST
Number of the M/s Sharma Traders has been verified from the GST Portal. On verification it is found
that the GST Number of M/s Sharma Traders being 07BOEPS6530Q1Z9 has been suspended with
effect from 05/07/2021.
You have not made any payment to M/s Sharma Traders during A.Y. 2021-22 and shown total
purchase amount as outstanding as on 31.03.2021. In view of the denial of the seller and suspension
of GST number, the purchase is not found genuine. In these circumstances, the genuineness and
creditworthiness of the purchase of Rs. 2736653/- from M/s Sharma Traders could not be proved.
In this regard you are hereby requested to explain as to why the purchase from M/s Sharma Traders
totaling to Rs. 2736653/- should not be treated as bogus expenditure and why it should not be added
to total income.
From your submission it is found that you have made purchase of Rs. 27042996/- from M/s Kavita
Enterprises.
You have not submitted any purchase bills, transportation details, delivery challans, bank details of the
seller regarding M/s Kavita Enterprises.
During the assessment proceedings for gathering information notice u/s 133(6) was issued to M/s
Kavita Enterprises on 15.11.2022. In response to the notice Shri Saurabh Sethi (Prop.-M/s Kavita
Enterprises) filed its reply on 28.11.2022.
Page 5 of 16
AKIPG0472G- PARUL GARG
A.Y. 2021-22
ITBA/AST/F/143(3)(SCN)/2022-23/1047807373(1)
We have no dealings with this Party. A fraud GST was obtained on my PAN in Delhi. Copy
of Complaint is enclosed.
As per your submission GST number of M/s Kavita Enterprises is 07BJPPS2286D1ZU.The GST
Number of the M/s Kavita Enterprises has been verified from the GST Portal. On verification it is found
that the GST Number of M/s Kavita Enterprises being 07BJPPS2286D1ZU has been Cancelled suo-
moto with effect from 15.12.2020.
In view of the denial of the seller and suspension of GST number, the purchase is not found genuine.
In these circumstances, the genuineness and creditworthiness of the purchase of Rs. 27042996/- from
M/s Kavita Enterprises could not be proved.
In this regard you are hereby requested to explain as to why the purchase from M/s Kavita Enterprises
totaling to Rs. 27042996/- should not be treated as bogus expenditure and why it should not be added
to total income.
From your submission it is found that you have made purchase of Rs. 7265334/- from M/s V G
Enterprises.
You have not submitted any purchase bills, transportation details, delivery challans, bank details of the
seller regarding M/s V G Enterprises.
During the assessment proceedings for gathering information notice u/s 133(6) was issued to M/s V G
Enterpriseson 15.11.2022. In response to the notice Shri Nitin Panwar(Prop.- M/s V G Enterprises)
filed its reply on 28.11.2022.
We have no dealings with this Party. A fraud GST was obtained on my PAN in Delhi. Copy
of Complaint is enclosed.
As per your submission GST number of M/s V G Enterprisesis 07BHAPP1428B1ZV. The GST
Number of the M/s V G Enterpriseshas been verified from the GST Portal. On verification it is found
that the GST Number of M/s V G Enterprises being 07BHAPP1428B1ZV has been Cancelled suo-
moto with effect from 28.12.2020.
In view of the denial of the seller and cancellation of GST number, the purchase is not found genuine.
In these circumstances, the genuineness and creditworthiness of the purchase of Rs. 7265334/- from
M/s V G Enterprises could not be proved.
In this regard you are hereby requested to explain as to why the purchase from M/s V G Enterprises
totaling to Rs. 7265334/- should not be treated as bogus expenditure and why it should not be added
to total income.
Page 6 of 16
AKIPG0472G- PARUL GARG
A.Y. 2021-22
ITBA/AST/F/143(3)(SCN)/2022-23/1047807373(1)
From your submission it is found that you have made purchase of Rs. 5406747/- from M/s Radhey
Radhey Marketing.
In response to the notice u/s 142(1), you have submitted the purchase ledgers. On perusal of the
purchase ledger it is found that you have made purchase of Rs. 5406747/- from M/s Radhey Radhey
Marketing (Prop.-Ajay Kumar Tomar).
You have not submitted any purchase bills, transportation details, delivery challans, bank details of the
seller regarding M/s Radhey Radhey Marketing.
During the assessment proceedings for gathering information notice u/s 133(6) was issued to M/s
Radhey Radhey Marketing on 15.11.2022. The date of compliance was fixed on 22.07.2022. But in
response to the notice no reply has been filed by Shri Ajay Kumar Tomar (Prop.-M/s Radhey Radhey
Marketing).
Thereafter, again a reminder notice u/s 133(6) was issued to the him on 30.11.2022 for filing reply on
or before 02.12.2022. But Shri Ajay Kumar Tomar has not filed any reply again. Thus M/s V G
Enterprises has not confirmed your transaction with it.
As per your submission GST number of M/s Radhey Radhey Marketing is 07ANXPT8409J1Z0. The
GST Number of the M/s Radhey Radhey Marketing has been verified from the GST Portal. On
verification it is found that the GST Number of M/s Radhey Radhey Marketing being
07ANXPT8409J1Z0 has been Cancelled suo-moto with effect from 25.01.2020. While from the ledger
accounts all the purchase bills are found for a later date.
Further on perusal of GSTR Form- 9C (Reconciliation Statement) for F.Y. 2020-21 it is found that
there is un-reconciled difference in Input Tax Credit.
M/s Radhey Radhey Marketing is one of those entity which ITC does not reflected and remained
unmatched.
In this facts and circumstances of the case, the purchase is not found genuine. In these
circumstances, the genuineness and creditworthiness of the purchase of Rs. 5406747/- from M/s
Radhey Radhey Marketing could not be proved.
In this regard you are hereby requested to explain as to why the purchase from M/s Radhey Radhey
Marketing totaling to Rs. 5406747/- should not be treated as bogus expenditure and why it should not
be added to total income.
From your submission it is found that you have made purchase of Rs. 3270806/- from M/s Bharti
Traders.
You have not submitted any purchase bills, transportation details, delivery challans, bank details of the
seller regarding M/s Bharti Traders.
During the assessment proceedings for gathering information notice u/s 133(6) was issued to M/s
Bharti Traders on 15.11.2022. The date of compliance was fixed on 22.07.2022. But in response to the
notice Shri Bharti (Prop.-M/s Bharti Traders) has not filed any reply.
Page 7 of 16
AKIPG0472G- PARUL GARG
A.Y. 2021-22
ITBA/AST/F/143(3)(SCN)/2022-23/1047807373(1)
Thereafter, again a reminder notice u/s 133(6) was issued to him on 30.11.2022 for filing reply on or
before 02.12.2022. But Shri Bharti has not filed any reply again. Thus M/s V G Enterprises has not
confirmed your transaction with it.
As per your submission GST number of M/s Bharti Traders is 07CDXPB2786E2Z7. The GST Number
of the M/s Bharti Traders has been verified from the GST Portal. On verification it is found that the
GST Number of M/s Bharti Traders being 07CDXPB2786E2Z7 has been Cancelled suo-moto with
effect from 23.09.2020. While from the ledger accounts all the purchase dates are found for a later
date.
Further on perusal of GSTR Form- 9C (Reconciliation Statement) for F.Y. 2020-21 it is found that
there is un-reconciled difference in Input Tax Credit.
M/s Bharti Traders is one of those entities which ITC does not reflected and remained unmatched.
In this facts and circumstances of the case, the purchase is not found genuine. In these
circumstances, the genuineness and creditworthiness of the purchase of Rs. 3270806/- from M/s
Bharti Traders could not be proved.
In this regard you are hereby requested to explain as to why the purchase from M/s Bharti Traders
totaling to Rs. 3270806/- should not be treated as bogus expenditure and why it should not be added
to total income.
From your submission it is found that you have made purchase of Rs. 3976989/- from M/s Mamta
Enterprise.
You have not submitted any purchase bills, transportation details, delivery challans, bank details of the
seller regarding M/s Sharma Traders.
During the assessment proceedings for gathering information notice u/s 133(6) was issued to M/s
Mamta Enterprises on 15.11.2022. The date of compliance was fixed on 22.07.2022. But in response
to the notice Shri Ajay Kumar Tomar (Prop.- M/s Mamta enterprises) has not filed any reply.
Thereafter, again a reminder notice u/s 133(6) was issued to the him on 30.11.2022 for filing reply on
or before 02.12.2022. But Shri Ajay Kumar Tomar has not filed any reply again.
As per your submission GST number of M/s Mamta Enterprises is 07FOXPD0578G7ZC. The GST
Number of the M/s Mamta Enterprises has been verified from the GST Portal. On verification it is
found that the GST Number of M/s Mamta Enterprises being 07FOXPD0578G7ZChas been cancelled
suo-moto with effect from 25.01.2020. While from the ledger accounts all the purchase bills are found
for a later date.
Further on perusal of GSTR Form- 9C (Reconciliation Statement) for F.Y. 2020-21 it is found that
there is un-reconciled difference in Input Tax Credit.
M/s Mamta Enterprises is one of those entity which ITC does not reflected and remained unmatched.
In this facts and circumstances of the case, the purchase is not found genuine. In these
circumstances, the genuineness and creditworthiness of the purchase of Rs. 3976989/- from M/s
Mamta Enterprises could not be proved.
Page 8 of 16
AKIPG0472G- PARUL GARG
A.Y. 2021-22
ITBA/AST/F/143(3)(SCN)/2022-23/1047807373(1)
In this regard you are hereby requested to explain as to why the purchase from M/s Mamta
Enterprises totaling to Rs. 3976989/- should not be treated as bogus expenditure and why it should
not be added to total income.
From your submission it is found that you have made purchase of Rs. 8297019/- from M/s G & V
Traders.
You have not submitted any purchase bills, transportation details, delivery challans, bank details of the
seller regarding M/s G & V Traders.
During the assessment proceedings for gathering information notice u/s 133(6) was issued to M/s G &
V Traders on 15.11.2022. The date of compliance was fixed on 22.07.2022. But in response to the
notice Shri Awadhesh Tiwari(Prop.- M/s G & V Traders) has not filed any reply.
Thereafter, again a reminder notice u/s 133(6) was issued to him on 30.11.2022 for filing reply on or
before 02.12.2022. But Shri Awadhesh Tiwari has not filed any reply again. Thus M/s G & V Traders
has not confirmed your transaction with it.
As per your submission GST number of M/s G & V Traders is 07AUWPT4209J2ZW. The GST Number
of the M/s G & V Traders has been verified from the GST Portal. On verification it is found that the
GST Number of M/s G & V Traders being 07AUWPT4209J2ZW has been cancelled suo-moto with
effect from 14.02.2021. While from the ledger accounts all the purchase bills are found for a later date.
Further on perusal of GSTR Form- 9C (Reconciliation Statement) for F.Y. 2020-21 it is found that
there is un-reconciled difference in Input Tax Credit.
M/s G & V Traders is one of those entities which ITC does not reflected and remained unmatched.
In this facts and circumstances of the case, the purchase is not found genuine. In these
circumstances, the genuineness and creditworthiness of the purchase of Rs. 8297019/- from M/s G &
V Traders could not be proved.
In this regard you are hereby requested to explain as to why the purchase from M/s G & V Traders
totaling to Rs. 8297019/- should not be treated as bogus expenditure and why it should not be added
to total income.
From your submission it is found that you have made purchase of Rs. 4727661/- from M/s Yak
Traders.
You have not submitted any purchase bills, transportation details, delivery challans, bank details of the
seller regarding M/s Sharma Traders.
During the assessment proceedings for gathering information notice u/s 133(6) was issued to M/s Yak
Traderson 15.11.2022. The date of compliance was fixed on 22.07.2022. But in response to the notice
Shri Chandro (Prop.-M/s Yak Traders) has not filed any reply.
Thereafter, again a reminder notice u/s 133(6) was issued to the him on 30.11.2022 for filing reply on
or before 02.12.2022. But Shri Chandrohas not filed any reply again. Thus M/s Yak Tradershas not
Page 9 of 16
AKIPG0472G- PARUL GARG
A.Y. 2021-22
ITBA/AST/F/143(3)(SCN)/2022-23/1047807373(1)
As per your submission GST number of M/s Yak Traders is 07BISPC6157R2ZD. The GST Number of
the M/s Yak Traders (Prop.-Chandro) has been verified from the GST Portal. On verification it is found
that the GST Number of M/s Yak Traders being 07BISPC6157R2ZD has been cancelled suo-moto
with effect from 22.12.2019. While from the ledger accounts all the purchase bills are found for a later
date.
In this facts and circumstances of the case, the purchase is not found genuine. In these
circumstances, the genuineness and creditworthiness of the purchase of Rs. 4727661/- from M/s Yak
Traders could not be proved.
In this regard you are hereby requested to explain as to why the purchase from M/s Yak Traders
totaling to Rs. 4727661/- should not be treated as bogus expenditure and why it should not be added
to total income.
1(9) From your submission it is found that you have made following purchase:-
Sl. Purchase
Name GST No.
No. Amount (Rs.)
06AAQPG5917J1ZE
M/s Garg Steel (Prop.- Manju Garg) (PAN -
2. 3020912
AAQPG5917J)
Page 10 of 16
AKIPG0472G- PARUL GARG
A.Y. 2021-22
ITBA/AST/F/143(3)(SCN)/2022-23/1047807373(1)
EHRPS0394M)
Vide this office notice u/s 142(1), you were requested to furnish all the purchase bills in support of the
purchase. But you have not filed all the purchase bills in the above mentioned cases. You have filed
the purchase bills in the case of M/s Ashanand Roshan Lal (P) Ltd. and M/s Garg Steel only. The total
purchase from M/s Ashanand Roshan Lal (P) Ltd. is Rs. 1671533/- and from M/s Garg Steel is Rs.
3020912/-. Thus, total purchase from these two persons come to Rs. 4692445/- for which you have
furnished purchased bills. Thus you have failed to furnish purchase bills for Rs. 89595056/-.
You have not furnished the stock register for A.Y. 2021-22. You were asked to furnish all the delivery
challans but you failed to furnish any challan. You were asked to furnish confirmation from all the parties
from whom you have made purchased during A.Y. 2021-22. But you have not furnished any
conformation of accounts from any persons.
You failed to furnish the details of bank accounts of all the sellers from whom you made purchase. You
were also asked to furnish sale invoices but you failed to furnish any sale invoices. In the case of M/s Sai
Traders and M/s Ganesh Industries , the PANs are not registered on e-filing portal and they appears to
be non-filer.
You have only submitted ledger accounts of the sellers from whom it has made purchase. Mere
submission of ledger accounts without supporting documents is not enough to prove the purchase. In
absence of any supporting evidences entire purchased of the assessee could not be proved. The
assessee has failed to prove that it has actually made the purchase.
Page 11 of 16
AKIPG0472G- PARUL GARG
A.Y. 2021-22
ITBA/AST/F/143(3)(SCN)/2022-23/1047807373(1)
In this facts and circumstances of the case, the purchase from the above-mentioned persons totaling
to Rs. 89595056/- is treated as unexplained expenditure and proposed to be added to the total income
of the assessee.
2. In your profit & Loss Accounts you have shown purchase at Rs. 12,98,45,204/- while in the annexure
attached with your reply you have shown your total purchase at Rs. 157313603/-.
Thus there is difference of Rs. 2,74,68,399/- between the amount shown in your ledger and the amount
shown in Profit & Loss Account.
In view of this, the difference amount of Rs. 2,74,68,399/- is proposed to be added to the total income.
You are requested to explain as to why the amount of Rs. 2,74,68,399/- should not be added to your total
income and charged to tax.
TOTAL 7082409
For Sundry Debtor at Sl. No. 01 i.e.- Atul Kumar you have not furnished any PAN of the parties. So their
identity could not be proved. Further you have not furnished any supporting documentary evidences to
prove the sale. So genuineness of the transaction has alos not proved.
Further for Sundry Debtor at Sl. No. 02 to 07, the PAN provided by you is not in the name of persons
mentioned by you. Further these PANs have no e-mail and they are not found to have been registered on
e-filing portal and as such they are non-filer. In view of these facts, identity, genuineness and
creditworthiness of transaction have not been proved. Yu have not furnished any supporting to prove the
sale.
Page 12 of 16
AKIPG0472G- PARUL GARG
A.Y. 2021-22
ITBA/AST/F/143(3)(SCN)/2022-23/1047807373(1)
In view of this, the outstanding balance of these sundry debtors totaling to Rs. 7082409/- is proposed to
be added to the total income.
You are requested to explain as to why the amount of Rs. 7082409/- should not be added to your total
income and charged to tax.
Sl. Purchase
Name GST No.
No. Amount (Rs.)
07CDXPB2786E2Z7
5. M/s Bharti Traders (Bharti) (CDXPB2786E) 3270806
Page 13 of 16
AKIPG0472G- PARUL GARG
A.Y. 2021-22
ITBA/AST/F/143(3)(SCN)/2022-23/1047807373(1)
06AAQPG5917J1ZE
M/s Garg Steel (Prop.- Manju Garg) (PAN -
10. 2996919
AAQPG5917J)
BDVPJ3780K)
07CIBPG9976N1ZH)
Page 14 of 16
AKIPG0472G- PARUL GARG
A.Y. 2021-22
ITBA/AST/F/143(3)(SCN)/2022-23/1047807373(1)
Kumar Pandey)
(PAN- EHGPP1376H)
TOTAL 191524227
Subject to the above remarks the total income of the assessee is computed as under:-
Rs. Rs.
You are requested to furnish your explanation along with supporting documentary evidences and
following information/documents .
You are requested to furnish your explanation on or before the fixed date along with supporting
documentary evidences failing which assessment may be completed without giving you any further
opportunity. Mere submission without supporting documentary evidences shall not suffice to prove your
submission.
Page 15 of 16
AKIPG0472G- PARUL GARG
A.Y. 2021-22
ITBA/AST/F/143(3)(SCN)/2022-23/1047807373(1)
You are hereby given an opportunity to show cause why proposed variation should not be made and
the assessment should not be completed accordingly.
3. Kindly submit your response through your registered e-filing account at www.incometax.gov.in by
11:00 hours of 12/12/2022, whereby you may either:-
4. In case no response is received by the given time and date, the assessment shall be finalized taking
into account the variation(s) stated above.
Assessment Unit
Income Tax Department
Digitally signed by
ASSESSMENT UNIT, INCOME
TAX DEPARTMENT
Date: 05-12-2022 16:31:40 IST
Page 16 of 16