ANNEXURE – XII

To,
The Assessing Officer
National E-assessment Centre (NEAC)
…………………………………………………

Subject.: Your  notice dated …………….. under section 143(2)(ii) in the case of M/s……………….

Dear Sir,

Kindly refer to your  notice dated …………….. under section 143(2)(ii) indicating to make addition to sales made by the assessee on the basis of record maintained by M/S. ……………………………

It is submitted that as per CIT v. Prabhat Oil Mils (1995) 52 TTJ (AHD-TRIB) 533, mere entries in the accounts of third party is not sufficient to prove that the assessee made sales outside his books and no addition can be made on this ground alone.

We hope that you will consider our reply. You are requested to drop the addition on above basis.

Thanking you
Yours faithfully
For ………………………….
[Authorized Representative]
Date : …………………..
Place : …………………..