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TMI Blog2018 (2) TMI 1201X X X X Extracts X X X X X X X X Extracts X X X X ..... us suppliers and thus failed to substantiate the purchases. The assessee is a trader and there could be no sales without purchases. Addition, which could be made, was to account for profit element embedded in these purchase transactions to factorize profit earned by assessee against purchase of material in the grey market and undue benefit of VAT against bogus purchases, which Ld. CIT(A) has r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessment u/s 143(3) read with Section 147 for the impugned AY on 24/03/2014 where the income of the assessee was determined at ₹ 10,72,49,883/- as against returned income of ₹ 1,43,838/- e-filed by the assessee on 25/09/2009. The return was initially processed u/s 143(1) but subjected to reassessment proceedings pursuant to receipt of certain information from Sales Tax Department th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essee contested the same with partial success before Ld. CIT (A) vide impugned order dated 26/02/2016 where the assessee raised similar contentions and asserted that without purchases there could not be any sales and therefore, full disallowance was not justified. The Ld. CIT(A) after appreciating the various judicial pronouncements and assessee s GP/NP rate of three years, restricted the said dis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 5. We have heard the rival contentions and perused the relevant material on record. We are convinced with the arguments of the revenue that the assessee has failed to discharge the primary onus of proving the purchases as it could not produce sufficient evidences to show actual delivery of material and also could not produce confirmatory letters from the alleged bogus suppliers and thus failed ..... X X X X Extracts X X X X X X X X Extracts X X X X
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