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TMI Blog2021 (3) TMI 162X X X X Extracts X X X X X X X X Extracts X X X X ..... action of the AO, however, it is a fact on record that the Assessing Officer has not disputed either the consumption of goods or sales effected by the assessee. Thus, it has to be accepted that the disputed purchases have entered assessee's stock and utilized in the manufacturing process and ultimately resulting in sales. Therefore, in such circumstances, only the profit element embedded in su ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ompany and is engaged in manufacturing and sale of Kraft Line bags and liners. For the assessment year under dispute, assessee filed its return of income on 13-01-2010 declaring total income of ₹ 12,40,189/- under the normal provisions and book profit at ₹ 15,73,309/- under the provisions of section115JB of the Income-tax Act, 1961. The return of income filed by the assessee was proces ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hus, ultimately, he treated the purchases of ₹ 1,65,094/- as non genuine and added back to the income of the assessee. Assessee contested aforesaid addition before learned Commissioner (Appeals). After considering the submissions of the assessee in the context of facts and materials on record, learned Commissioner (Appeals) restricted the addition to 12.5% of the alleged non genuine purchase ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessing Officer has not disputed either the consumption of goods or sales effected by the assessee. Thus, it has to be accepted that the disputed purchases have entered assessee's stock and utilized in the manufacturing process and ultimately resulting in sales. Therefore, in such circumstances, only the profit element embedded in such purchases can be considered for addition. That being the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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