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TMI Blog2021 (9) TMI 210X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee had purchased the goods, possibly from unverified sources, has not been disputed by the Assessing Officer since he has accepted that the disputed goods representing such purchases were in possession of the assessee. Therefore, instead of disallowing the entire purchases, he has restricted the disallowance to gross profit rate declared by the assessee. Whereas, learned Commissioner (A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ioner (Appeals) in the matter of addition made on account of non genuine purchases. 3. Brief facts, which are common in both the appeals are, the assessee, an individual, is stated to be engaged in the business of trading in textiles. For the assessment years under consideration, the assessee had filed his returns of income in regular course which were processed under section 143(1) of the Act. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the genuineness of purchases also returned back un served. Thus, the Assessing Officer ultimately concluded that the purchases are non genuine. However, considering the fact that the assessee had effected corresponding sales, the Assessing Officer concluded that the assessee was in possession of the disputed goods. Therefore, instead of disallowing the entire purchases, he disallowed 20% and 21.2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ct that the assessee had purchased the goods, possibly from unverified sources, has not been disputed by the Assessing Officer since he has accepted that the disputed goods representing such purchases were in possession of the assessee. Therefore, instead of disallowing the entire purchases, he has restricted the disallowance to gross profit rate declared by the assessee. Whereas, learned Commissi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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