9911796707
TMI Blog2021 (3) TMI 1125X X X X Extracts X X X X X X X X Extracts X X X X ..... raised by the Revenue are hence, rejected. X X X X Extracts X X X X X X X X Extracts X X X X ..... of assessment proceedings called upon the assessee to give details of sundry creditors, purchases exceeding sum of ₹ 50,000/- and details of purchases above ₹ 01 Lakh made during the year. In response thereto, the assessee filed reply furnishing the details as called for. While framing the assessment, the Assessing Officer doubted the genuineness of purchases made by the assessee from three parties namely M/s. Heramani Impacts; M/s. Pooja Fashions & M/s. P. S. Expo Fabric Pvt.Ltd. After examination of details filed by two parties, the Assessing Officer disallowed the purchases made on the following grounds:- (i) "All the three parties are running their business from D-193, Gali No.8, Laxmi Nagar, Delhi-110092. However, the pre ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... such the premises was locked. Ld DR. further submitted that it was incumbent upon the assessee to prove the purchases. The assessee has miserably failed to dispel the suspicion of the Assessing Officer that the purchases were bogus. Ld. DR further submitted that the Ld. CIT(A) has failed to take note of the fact that parties were not having sufficient funds to make purchases. Therefore, the Assessing Officer was justified in making the disallowance and adding the same in the income of the assessee. 6. Per contra, the Ld. Counsel for the assessee opposed these submissions and supported the order of the Ld. CIT(A). Ld. Counsel for the assessee further took us through the assessment order as well as impugned order to buttress the contention ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ch in amount paid to related parties u/s 40(A)(2)(b). I find that no adverse inference has been drawn by the Assessing Officer specifically with regard to the above three parameters. 4.3.7. I find that the appellant had made purchases of ₹ 11,07,31,239/-. Out of these, purchases of the value of ₹ 2,04,36,629/- have been doubted by the AO, for reasons which do not stand judicial scrutiny. The aforesaid three persons have duly confirmed the sales. The appellant who is the buyer has also confirmed the purchases. Payments have been made by account payee cheques. The sellers have sold good to several buyers and received cheques in their respective bank accounts. The evidence of dispatch of goods and receipt of goods has been ..... X X X X Extracts X X X X X X X X Extracts X X X X
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