Assessee failed to substantiate the difference between purchases...

Assessee failed to substantiate the difference between purchases shown in its Profit and Loss Account and TCS reflected in Form 26AS. Sample bills showed invoices raised in sister concerns' names with assessee's PAN, and payments reflected in sister concerns' bank accounts. Lower authorities ignored vital documents produced. ITAT restored the issue to AO, directing opportunity to assessee to substantiate that purchases were made by sister concerns reflecting in their accounts, paid from their bank accounts. AO may ask assessee to furnish voluminous details before verification unit and call report. AO to decide as per facts and law after due opportunity to assessee, who must appear without adjournment, else AO can pass appropriate order. Grounds allowed for statistical purposes.