JUDGMENT

Kalpesh Satyendra Jhaveri, J. - By way of this appeal, the appellant has challenged the judgment and order of the Tribunal whereby the Tribunal has dismissed the appeal filed by the assessee.

2. Counsel for the appellant has framed the following questions of law:-

(i) Whether the ld. ITAT was justified under law while passing of the impugned order dated 18.12.2017 without applying its mind and by merely reproducing the contents of order passed in its own earlier judgment in ITAT No. 702/JP/2014 titled ACT Circle I, Jaiur vs. Bright Metals Indian Pvt. Ltd. Jaipur dated 24.02.2017 and simply recording that the assessee company being a private limited company the burden of proof on higher pedestal ignoring the law laid down by Hon'ble Apex Court in various cases referred in the impugned order itself particularly at page 9 & 11 of the impugned order?

(ii) Whether the Id. ITAT was justified under law while confirming the findings of the authorities below it by ignoring the fact that the assessee- company has furnished the detail particulars of the bank accounts, passport, PA