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2012 (2) TMI 69

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..... :- Assessing authority has listed a series of deficiencies in the documentation, but if the entire purchase made from the sundry parties has to be disallowed, the quantum of purchase of firewood available with the assessee would be quite insufficient to meet its operational requirements. Secondly, in the matter of purchase of firewood etc., there is every chance for making local purchase off and o .....

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..... nnai dated 21.01.2010. The appeal arises out of the assessment completed under sec. 143(3) of the Income-tax Act, 1961. 2. The first issue raised in the appeal is that the Commissioner of Income-tax (Appeals) has erred in upholding the addition of Rs. 24,69,070/- against the claim of expenditure made by the Revenue towards purchase or firewood. The assessee is basically a manufacturer of inorgan .....

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..... in reason for disallowance is that the majority of the invoices were selfmade vouchers. Many of the vehicles which were reflected in the vouchers were found to be auto-rickshaws while enquiring from the office of the RTO on a sample basis. It is for this and other reasons that the purchases from sundry parties have been disallowed by the assessing authority. The same has been confirmed by the Comm .....

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..... , in the matter of purchase of firewood etc., there is every chance for making local purchase off and on, for which foolproof and formal documentary evidences in the form of bills may not be available. Therefore, it is not proper on the part of the lower authorities to disallow the entire purchases made from sundry parties as bogus. Therefore, we find that the disallowance of Rs. 24,69,070/- as a .....

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