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TMI Blog2019 (8) TMI 1634X X X X Extracts X X X X X X X X Extracts X X X X ..... ani Bhadra Sales Pvt. Ltd. and in that eventuality, the assessee would prove that these material of purchases were consumed or not - HELD THAT:- Admittedly, the assessee is a manufacturer of analytical, environmental pollution monitoring instruments, Waste Water Treatment Applications, and services for monitoring and control of quality of gases, liquids, air and water. If, assessee made purchases ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sioner of Income Tax, Circle-3, Thane (in short ACIT/ AO) for the A.Y. 2009-10 vide order dated 27.02.2015, under section 143(3) read with section 147 of the Income-tax Act, 1961 (hereinafter the Act ). 2. The only issue in this appeal of assessee is against the order of CIT(A) confirming the addition of alleged bogus purchases. For this assessee has raised the following three grounds: - 1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... no necessity or any reason for the Appellant to indulge in activity of bogus purchases as alleged by the department. 3. Without prejudice to the above ground on the facts and circumstances of case and in law the Learned CIT(A) further erred in confirming 100% disallowance of purchase ₹ 21,03,678/- as against 25% / 12.5% disallowance of unverifiable purchases as upheld by the various cour ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rred the appeal before CIT(A). The CIT(A) confirmed the addition on the basis that the assessee is unable to prove the consumption of the items because the assessee is a contractor. 4. Even now before us, the learned Sr. Departmental Representative stated that the assessee is unable to prove the consumption and in case the assessee prove consumption, the matter can be decided by applying the pr ..... X X X X Extracts X X X X X X X X Extracts X X X X
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