Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 372/Rjt/ 2023 ("नधा"रणवष" / Assessment Year: (2013-14) Lilavantiben Gordhanbhai Padariya Vs. Ito, Wd – 1(1)(3), Rajkot Vrajdham, Shardanagar Main Road, Aayakar Bhavan, Race Course Mabdi Road, Rajkot – 360001 Ring Road, Rajkot – 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acgpp7067E (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld.Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 24/06/2025 Date Of Pronouncement : 19/09/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm: Captioned Appeal Filed By The Assessee Is Directed Against The Order Passed By The National Faceless Appeal Centre [(In Short “Nfac/Ld. Cit(A)”] Vide Order Dated 09.09.2023, Which In Turn Assessment Order Passed By Assessment Unit, Income Tax Department / Assessing Officer Under Section 143(3) R.W.S. 147 Of The Income Tax Act, 1961 (In Short “The Act”), Vide Order Dated 04.12.2017. 2. Grounds Of The Appeal Raised By The Assessee Are As Follows: 1. The Learned Commissioner (Appeals), National Faceless Appeal Centre, Delhi Erred In Upholding Validity Of Assessment U/S 147 By Issue Of Notice U/S 148 Of The Act. 2 The Learned Commissioner (Appeals), National Faceless Appeal Centre, Delhi Erred In Confirming Action Of Assessing Officer In Making Addition Of Rs. 1,11,13,196/- By Way Of Alleged Difference Between Sales As Per Annual Vat Return & Sales As Per Audited Accounts By Failing To Appreciate That The Alleged Difference Was Duly Reconciled & Explained.

reassessment proceedings. the appellant clarified that the alleged difference of Rs. 1,11,13,196/- is due to inclusion of Excise Duty component in the Turnover reported in the Annual Return filed before the sales-tax (VAT) Department It was also submitted that in the audited financial statements, component of excise duty passed on to the customer is shown