BharatTax.net
SearchITATHigh CourtsSupreme CourtPhrasesAI ResearchHistory

Filters

BharatTax.net

Free search engine for ITAT (Income Tax Appellate Tribunal) judgments across all 28 benches in India.

Quick Links

  • Search Judgments
  • Browse by Bench
  • Recent Judgments

About

BharatTax provides free access to Income Tax Appellate Tribunal orders for legal research and reference.

© 2026 BharatTax.net. All rights reserved.

56 results for “disallowance”+ Bogus Purchasesclear

Sorted by relevance

Mumbai6,107Delhi1,898Kolkata786Ahmedabad503Jaipur496Chennai473Surat385Pune371Bangalore296Chandigarh243Hyderabad194Indore162Raipur133Amritsar99Nagpur93Lucknow72Rajkot71Cuttack67Cochin64Visakhapatnam56Guwahati55Calcutta52Allahabad33Agra32Jodhpur32Ranchi22Dehradun14Karnataka13Patna11Jabalpur5Panaji5Telangana4SC3Orissa3Varanasi2Gauhati1Punjab & Haryana1Bombay1ASHOK BHAN DALVEER BHANDARI1

Key Topics

Section 143(3)57Addition to Income35Section 13229Section 153A28Section 143(2)27Section 10A21Section 142(1)20Section 14A20Disallowance

SMT. L SUDHA BALA, L/R OF LATE SRI L.NARSA REDDY,GUNTUR vs. THE DCIT, SPECIAL RANGE GUNTUR, GUNTUR

In the result, the appeals of the assessee are dismissed

ITA 261/VIZ/2012[1985-86]Status: DisposedITAT Visakhapatnam07 Dec 2018AY 1985-86

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.260 & 261/Viz/2012 (धििाारण िर्ा/ Assessment Years :1984-85 & 1985-86 Respectively) L.Sudha Bala Vs. Dy.Commissioner Of L/R Of Late Sri L Narasa Reddy Income Tax Prop.Sri Venkateswara Agro Chemicals Special Range Industries Guntur 2-14-101, Syamala Nagar 2Nd Lane, Guntur [Pan : Acgpl2351P] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri C.Subrahmanyam, ARFor Respondent: Smt. Suman Malik, DR
Section 143(3)Section 147Section 148Section 40A(3)

purchases as well as the disallowance u/s 40A(3) of the IT Act, hence, the Ld.AR’s contention that the addition was made on account of disallowance u/s 40A(3) alone is incorrect and for the sake of repetition we observe that the AO has made the addition of the same amount on account of bogus

Showing 1–20 of 56 · Page 1 of 3

17
Search & Seizure17
Section 13115
Bogus Purchases9

SMT. L SUDHA BALA, L/R OF LATE SRI L.NARSA REDDY,GUNTUR vs. THE DCIT, SPECIAL RANGE GUNTUR, GUNTUR

In the result, the appeals of the assessee are dismissed

ITA 260/VIZ/2012[1984-85]Status: DisposedITAT Visakhapatnam07 Dec 2018AY 1984-85

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.260 & 261/Viz/2012 (धििाारण िर्ा/ Assessment Years :1984-85 & 1985-86 Respectively) L.Sudha Bala Vs. Dy.Commissioner Of L/R Of Late Sri L Narasa Reddy Income Tax Prop.Sri Venkateswara Agro Chemicals Special Range Industries Guntur 2-14-101, Syamala Nagar 2Nd Lane, Guntur [Pan : Acgpl2351P] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri C.Subrahmanyam, ARFor Respondent: Smt. Suman Malik, DR
Section 143(3)Section 147Section 148Section 40A(3)

purchases as well as the disallowance u/s 40A(3) of the IT Act, hence, the Ld.AR’s contention that the addition was made on account of disallowance u/s 40A(3) alone is incorrect and for the sake of repetition we observe that the AO has made the addition of the same amount on account of bogus

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

ITA 144/VIZ/2025[2012-13]Status: DisposedITAT Visakhapatnam13 May 2025AY 2012-13

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Shri MV Prasad, CAFor Respondent: Dr Satyasai Rath, CIT(DR)
Section 127Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 245C(1)Section 245D

bogus and hence, interest paid on term loan utilized for the purpose also calls for disallowance and therefore, issued a show cause notice dated 06/12/2012 requiring the assessee to show cause as to why the corresponding expenditure should not be disallowed. The assessee vide its reply submitted that even though the funds towards purchase

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

ITA 140/VIZ/2025[2008-09]Status: DisposedITAT Visakhapatnam13 May 2025AY 2008-09

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Shri MV Prasad, CAFor Respondent: Dr Satyasai Rath, CIT(DR)
Section 127Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 245C(1)Section 245D

bogus and hence, interest paid on term loan utilized for the purpose also calls for disallowance and therefore, issued a show cause notice dated 06/12/2012 requiring the assessee to show cause as to why the corresponding expenditure should not be disallowed. The assessee vide its reply submitted that even though the funds towards purchase

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

ITA 141/VIZ/2025[2009-10]Status: DisposedITAT Visakhapatnam13 May 2025AY 2009-10

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Shri MV Prasad, CAFor Respondent: Dr Satyasai Rath, CIT(DR)
Section 127Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 245C(1)Section 245D

bogus and hence, interest paid on term loan utilized for the purpose also calls for disallowance and therefore, issued a show cause notice dated 06/12/2012 requiring the assessee to show cause as to why the corresponding expenditure should not be disallowed. The assessee vide its reply submitted that even though the funds towards purchase

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

ITA 143/VIZ/2025[2011-12]Status: DisposedITAT Visakhapatnam13 May 2025AY 2011-12

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Shri MV Prasad, CAFor Respondent: Dr Satyasai Rath, CIT(DR)
Section 127Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 245C(1)Section 245D

bogus and hence, interest paid on term loan utilized for the purpose also calls for disallowance and therefore, issued a show cause notice dated 06/12/2012 requiring the assessee to show cause as to why the corresponding expenditure should not be disallowed. The assessee vide its reply submitted that even though the funds towards purchase

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

ITA 142/VIZ/2025[2010-11]Status: DisposedITAT Visakhapatnam13 May 2025AY 2010-11

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Shri MV Prasad, CAFor Respondent: Dr Satyasai Rath, CIT(DR)
Section 127Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 245C(1)Section 245D

bogus and hence, interest paid on term loan utilized for the purpose also calls for disallowance and therefore, issued a show cause notice dated 06/12/2012 requiring the assessee to show cause as to why the corresponding expenditure should not be disallowed. The assessee vide its reply submitted that even though the funds towards purchase

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), VIJAYAWADA, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

ITA 37/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam30 Jun 2025AY 2017-18

Bench: Us:

For Appellant: None
Section 131Section 147

purchase bills to various entities and there was not actual supply of goods. He also mentioned that he controlled and managed the company M/s. Aneri Fincap Ltd. which is a paper company and not doing any genuine business activity and was only engaged in providing bogus accommodation entries to various beneficiaries. 6.3 The appellant during the year has taken loan

THE INCOME TAX OFFICER, CIRCLE-1(1), VIJAYAWADA, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

ITA 35/VIZ/2025[2014-15]Status: DisposedITAT Visakhapatnam30 Jun 2025AY 2014-15

Bench: Us:

For Appellant: None
Section 131Section 147

purchase bills to various entities and there was not actual supply of goods. He also mentioned that he controlled and managed the company M/s. Aneri Fincap Ltd. which is a paper company and not doing any genuine business activity and was only engaged in providing bogus accommodation entries to various beneficiaries. 6.3 The appellant during the year has taken loan

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), VIJAYAWADA, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

ITA 38/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam30 Jun 2025AY 2017-18

Bench: Us:

For Appellant: None
Section 131Section 147

purchase bills to various entities and there was not actual supply of goods. He also mentioned that he controlled and managed the company M/s. Aneri Fincap Ltd. which is a paper company and not doing any genuine business activity and was only engaged in providing bogus accommodation entries to various beneficiaries. 6.3 The appellant during the year has taken loan

ACIT, CIRCLE-1(1),, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

ITA 36/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam30 Jun 2025AY 2016-17

Bench: Us:

For Appellant: None
Section 131Section 147

purchase bills to various entities and there was not actual supply of goods. He also mentioned that he controlled and managed the company M/s. Aneri Fincap Ltd. which is a paper company and not doing any genuine business activity and was only engaged in providing bogus accommodation entries to various beneficiaries. 6.3 The appellant during the year has taken loan

ACIT, CIRCLE-1(1), VIJAYAWADA, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

ITA 34/VIZ/2025[2013-14]Status: DisposedITAT Visakhapatnam30 Jun 2025AY 2013-14

Bench: Us:

For Appellant: None
Section 131Section 147

purchase bills to various entities and there was not actual supply of goods. He also mentioned that he controlled and managed the company M/s. Aneri Fincap Ltd. which is a paper company and not doing any genuine business activity and was only engaged in providing bogus accommodation entries to various beneficiaries. 6.3 The appellant during the year has taken loan

PENMATSA PRASAD RAJU,BHIMAVARAM vs. INCOME TAX OFFICER, WARD-1, BHIMAVARAM

In the result, appeal of the revenue is allowed for statistical purposes

ITA 517/VIZ/2024[2022-23]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2022-23

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.517/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2022-23) Vs. Income Tax Officer-Ward – 1 Penmatsa Prasad Raju D.No. 7-7-25/3 Income Tax Office Kodavalli Road, Fci Colony Aayakar Bhavan Bhimavaram – 534201 Jp Road, Sivaraopet Andhra Pradesh Bhimavaram – 534201 Andhra Pradesh [Pan:Aqcpp6707B] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपीलसं./I.T.A.No.33/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2022-23) Vs. Penmatsa Prasad Raju Income Tax Officer D.No. 7-7-25/3 Income Tax Office Kodavalli Road, Fci Colony Aayakar Bhavan Bhimavaram – 534201 Opp. Ganesh Canteen Andhra Pradesh Jp Road, Sivaraopet Bhimavaram – 534202 [Pan:Aqcpp6707B] Andhra Pradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Gvn Hari, Advocate करदाता का प्रतततितित्व/ Assessee Represented By राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

Section 142(1)Section 143(1)(a)Section 143(2)Section 144

purchases claimed, Ld. AO has rightly disallowed 25% as bogus purchases. However, he further submitted that Ld.CIT(A) has erred

INCOMETAX OFFICER , BHIMAVARAM vs. PRASAD RAJU PENMATSA, BHIMAVARAM

In the result, appeal of the revenue is allowed for statistical purposes

ITA 33/VIZ/2025[2022-23]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2022-23

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.517/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2022-23) Vs. Income Tax Officer-Ward – 1 Penmatsa Prasad Raju D.No. 7-7-25/3 Income Tax Office Kodavalli Road, Fci Colony Aayakar Bhavan Bhimavaram – 534201 Jp Road, Sivaraopet Andhra Pradesh Bhimavaram – 534201 Andhra Pradesh [Pan:Aqcpp6707B] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपीलसं./I.T.A.No.33/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2022-23) Vs. Penmatsa Prasad Raju Income Tax Officer D.No. 7-7-25/3 Income Tax Office Kodavalli Road, Fci Colony Aayakar Bhavan Bhimavaram – 534201 Opp. Ganesh Canteen Andhra Pradesh Jp Road, Sivaraopet Bhimavaram – 534202 [Pan:Aqcpp6707B] Andhra Pradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Gvn Hari, Advocate करदाता का प्रतततितित्व/ Assessee Represented By राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

Section 142(1)Section 143(1)(a)Section 143(2)Section 144

purchases claimed, Ld. AO has rightly disallowed 25% as bogus purchases. However, he further submitted that Ld.CIT(A) has erred

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR vs. POLISETTY SOMASUNDARAM PVT LTD, GUNTUR

In the result, appeal of the Revenue is dismissed and the Cross Objection raised by the assessee is disposed off as mentioned herein above

ITA 248/VIZ/2022[2015-16]Status: DisposedITAT Visakhapatnam31 Oct 2023AY 2015-16

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. No.248/Viz/2022 ("नधा"रण वष" / Assessment Year :2015-16) The Deputy Commissioner Of Vs. M/S. Polisetty Income Tax, Central Circle-1, Somasundaram Pvt Ltd., 3Rd Floor, Rajkamal Complex, D.No. 3-30-17, Sundaram Lakshmipuram Main Road, Colony, Ring Road, Guntur-522 007, Gujjanagundla, Guntur, Andhra Pradesh. Andhra Pradesh-522006. Pan: Aabcp 3168 Q (अपीलाथ"/ Appellant) (""यथ"/ Respondent) C.O. No. 03/Viz/2023 (In आयकर अपील सं./ I.T.A. No.248/Viz/2022) ("नधा"रण वष" / Assessment Year :2015-16) M/S. Polisetty Somasundaram Pvt Vs. The Deputy Commissioner Of Ltd., Income Tax, Central Circle-1, D.No. 3-30-17, Sundaram Colony, 3Rd Floor, Rajkamal Complex, Ring Road, Gujjanagundla, Lakshmipuram Main Road, Guntur, Andhra Pradesh-522006. Guntur-522 007, Pan: Aabcp 3168 Q Andhra Pradesh. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Assessee By : Sri Gvn Hari, Ar ""याथ" क" ओर से / Revenue By : Dr Satya Sai Rath, Cit-Dr

For Appellant: Sri GVN Hari, ARFor Respondent: Dr Satya Sai Rath, CIT-DR
Section 132Section 132(4)Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153A

disallowed as no expenses have been claimed under the head purchases by the appellant for the purpose of computation of income under the Act……….” 7. Further, we find that the Ld. AO has not brought on record any material to corroborate the seized material warranting addition of bogus

SHYAM SUNDAR POLISETTY,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal filed by the assessee for the AY 2013-

ITA 260/VIZ/2023[2013-14]Status: DisposedITAT Visakhapatnam28 Feb 2024AY 2013-14

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. Nos. 260 To 267/Viz/2023 ("नधा"रण वष" / Assessment Years: 2013-14 To 2020-21)

For Appellant: Sri M.V. Prasad, ARFor Respondent: Dr. Satyasai Rath, CIT-DR
Section 127Section 132Section 143(3)Section 153A

disallowed in the hands of M/s. Polisetty Somasundaram firm and since the impugned expenditure is not allowable in the hands of the firm, taxing the same in the hands of the partner would amount to double addition and therefore, the Ld.AO made an addition of Rs. 2,25,13,508/- on protective basis towards withdrawal from M/s. Polisetty Somasundaram treating

SHYAM SUNDAR POLISETTY ,GUNTUR vs. DEPUTY COMMISIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal filed by the assessee for the AY 2013-

ITA 261/VIZ/2023[2014-15]Status: DisposedITAT Visakhapatnam28 Feb 2024AY 2014-15

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. Nos. 260 To 267/Viz/2023 ("नधा"रण वष" / Assessment Years: 2013-14 To 2020-21)

For Appellant: Sri M.V. Prasad, ARFor Respondent: Dr. Satyasai Rath, CIT-DR
Section 127Section 132Section 143(3)Section 153A

disallowed in the hands of M/s. Polisetty Somasundaram firm and since the impugned expenditure is not allowable in the hands of the firm, taxing the same in the hands of the partner would amount to double addition and therefore, the Ld.AO made an addition of Rs. 2,25,13,508/- on protective basis towards withdrawal from M/s. Polisetty Somasundaram treating

SHYAM SUNDAR POLISETTY ,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal filed by the assessee for the AY 2013-

ITA 266/VIZ/2023[2019-20]Status: DisposedITAT Visakhapatnam28 Feb 2024AY 2019-20

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. Nos. 260 To 267/Viz/2023 ("नधा"रण वष" / Assessment Years: 2013-14 To 2020-21)

For Appellant: Sri M.V. Prasad, ARFor Respondent: Dr. Satyasai Rath, CIT-DR
Section 127Section 132Section 143(3)Section 153A

disallowed in the hands of M/s. Polisetty Somasundaram firm and since the impugned expenditure is not allowable in the hands of the firm, taxing the same in the hands of the partner would amount to double addition and therefore, the Ld.AO made an addition of Rs. 2,25,13,508/- on protective basis towards withdrawal from M/s. Polisetty Somasundaram treating

SHYAM SUNDAR POLISETTY,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal filed by the assessee for the AY 2013-

ITA 265/VIZ/2023[2018-19]Status: DisposedITAT Visakhapatnam28 Feb 2024AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. Nos. 260 To 267/Viz/2023 ("नधा"रण वष" / Assessment Years: 2013-14 To 2020-21)

For Appellant: Sri M.V. Prasad, ARFor Respondent: Dr. Satyasai Rath, CIT-DR
Section 127Section 132Section 143(3)Section 153A

disallowed in the hands of M/s. Polisetty Somasundaram firm and since the impugned expenditure is not allowable in the hands of the firm, taxing the same in the hands of the partner would amount to double addition and therefore, the Ld.AO made an addition of Rs. 2,25,13,508/- on protective basis towards withdrawal from M/s. Polisetty Somasundaram treating

SHYAM SUNDAR POLISETTY,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal filed by the assessee for the AY 2013-

ITA 264/VIZ/2023[2017-18]Status: DisposedITAT Visakhapatnam28 Feb 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. Nos. 260 To 267/Viz/2023 ("नधा"रण वष" / Assessment Years: 2013-14 To 2020-21)

For Appellant: Sri M.V. Prasad, ARFor Respondent: Dr. Satyasai Rath, CIT-DR
Section 127Section 132Section 143(3)Section 153A

disallowed in the hands of M/s. Polisetty Somasundaram firm and since the impugned expenditure is not allowable in the hands of the firm, taxing the same in the hands of the partner would amount to double addition and therefore, the Ld.AO made an addition of Rs. 2,25,13,508/- on protective basis towards withdrawal from M/s. Polisetty Somasundaram treating